In the case of Kossick v. United Fruit Co., 1960, Joseph Kossick sued his employer, United Fruit Company for injuries he sustained while working on one of their ships. The Supreme Court had to decide whether a seaman could recover damages under general maritime law for negligence and unseaworthiness when the injury occurred in foreign waters but was caused by inadequate medical treatment provided by an American doctor aboard an American ship. The court ruled that U.S. laws did apply because the relationship between Mr. Kossick and his employer was based on a contract made in New York which stipulated that any disputes would be settled according to U.S law regardless of where they arose or where the alleged negligence took place.

In the dissenting opinion for Kossick v. United Fruit Co., Justice Frankfurter disagreed with the majority's interpretation of maritime law and its application to this case. He argued that a seaman’s right to maintenance and cure, which is an obligation of a shipowner to provide medical care for injuries or illnesses incurred while in service, should not be extended beyond traditional boundaries established by previous court rulings. In his view, Mr. Kossick's treatment did not fall within these parameters because it was neither emergency nor necessary treatment at sea but rather elective surgery performed onshore long after he had left the vessel’s service. Furthermore, he contended that expanding such rights could potentially lead to abuse as seamen might seek unnecessary treatments knowing they would be covered under maintenance and cure provisions.