In the 1959 case of Marine Cooks & Stewards, AFL v. Panama Steamship Co., Ltd., the Supreme Court ruled in favor of Panama Steamship Company and against the labor union, Marine Cooks & Stewards (MCS). The MCS had filed a lawsuit claiming that they were entitled to damages due to breach of contract by Panama Steamship Company. However, it was found that there was no contractual relationship between MCS and Panama Steamship as their agreement was with another entity - Pacific Maritime Association (PMA), which acted on behalf of its members including the steamship company. Therefore, any claim for damages should have been directed towards PMA rather than individual member companies like Panama Steamship Co. This ruling clarified an important aspect regarding collective bargaining agreements and who is liable under such contracts.

In the dissenting opinion for Marine Cooks & Stewards, AFL v. Panama Steamship Co., Ltd., Justice Brennan argued that the majority's decision was inconsistent with previous rulings and federal labor policy. He contended that the National Labor Relations Act (NLRA) should apply to foreign-flag ships when they are in U.S waters if their crew members are American citizens or residents. The NLRA aims to protect workers' rights, including collective bargaining and forming trade unions; therefore, it should cover these seamen who work on foreign vessels but live in America. Furthermore, he disagreed with the majority's view that applying domestic law would interfere with international comity because other nations also regulate working conditions aboard ships within their jurisdiction regardless of flag nationality.