In the case of James F. Lewis v. Lewis & Clark Marine, Inc., 2000, the U.S. Supreme Court addressed whether a federal court could exercise jurisdiction over an in rem admiralty action when it had been filed concurrently with an ongoing state proceeding involving the same incident and parties. The dispute arose from a barge collision on the Mississippi River which led to two separate lawsuits - one in Missouri state court by injured workers against their employer (Lewis & Clark Marine), and another in federal district court by Lewis & Clark seeking limitation of liability under federal maritime law. The Supreme Court held that there was no "inflexible rule" requiring dismissal or stay of such actions due to concurrent state proceedings; instead, lower courts should use discretion based on principles like wise judicial administration and comprehensive disposition of litigation.

In the dissenting opinion for James F. Lewis v. Lewis & Clark Marine, Inc., Justice Ginsburg disagreed with the majority's interpretation of Section 3 of the Federal Arbitration Act (FAA). She argued that this section does not mandate a stay in proceedings when there is an issue referable to arbitration under an agreement in writing. Instead, she believed it merely permits such a stay at the discretion of district courts. According to her view, nothing in FAA’s text or legislative history supports reading "may" as "must." Furthermore, she contended that compelling federal courts to halt proceedings whenever there is a pending arbitration undermines Congress' intent behind enacting FAA - facilitating voluntary agreements for private dispute resolution without unduly burdening litigation process if one party resists arbitration.