In the 1942 case of Marshall, Deputy Commissioner, U.S. Employees' Compensation Commission et al. v. Pletz, the United States Supreme Court ruled on a dispute involving workers' compensation for federal employees injured while working overseas. The plaintiff was an employee of a private company contracted by the government who had been injured in Canada and sought to claim benefits under the U.S Federal Employees' Compensation Act (FECA). The court held that FECA did not apply extraterritorially to injuries sustained outside of the United States unless explicitly stated within individual contracts or agreements with employers. This ruling clarified that domestic laws do not automatically extend beyond national borders without explicit provisions stating otherwise.

In the dissenting opinion for Marshall, Deputy Commissioner, U.S. Employees' Compensation Commission et al. v. Pletz (1942), Justice Frank Murphy argued that the majority's decision to deny compensation benefits was unjust and contrary to the spirit of the Longshoremen's and Harbor Workers' Compensation Act under which this case fell. He contended that Mr. Pletz should be entitled to disability benefits because his work-related injury had aggravated a pre-existing condition leading to total disability, even though he could have theoretically performed some other type of work in his impaired state. According to Justice Murphy, it is not enough for an injured worker merely being able physically perform another job; rather they must also be realistically employable considering factors such as age, education level and employment opportunities available in their community.