In the case of Johnson v. Atlantic, Gulf and West India Transit Company in 1894, the U.S Supreme Court ruled on a dispute involving maritime law. The plaintiff, Johnson, was injured while working as a longshoreman for the defendant company when he fell into an open hatchway that had been left unguarded. He sued for damages under general maritime law and won his case at trial court level. However, upon appeal to the Supreme Court by the transit company arguing that they were not liable because their duty to provide safe conditions did not extend to independent contractors like Johnson who were aware of potential dangers involved in their work. The Supreme Court disagreed with this argument and upheld lower courts' decisions favoring Johnson's claim for compensation from his employers due to negligence causing injury during employment. They stated that it is indeed within an employer’s responsibility under maritime law to ensure safety measures are taken even if workers are aware of possible risks associated with their job duties.

In the dissenting opinion for Johnson v. Atlantic, Gulf and West India Transit Company, it was argued that the majority's decision to hold a ship owner liable for injuries sustained by a worker due to defective equipment provided by another party was incorrect. The dissent contended that while an employer has a duty of care towards its employees, this does not extend to guaranteeing the safety of tools or machinery supplied by third parties. It further asserted that if such liability were imposed on employers, it would be excessively burdensome and could potentially discourage business operations altogether. Moreover, it emphasized that there should be clear evidence showing negligence on part of the employer in order to establish liability; mere occurrence of an accident is insufficient proof thereof.