The U.S. Supreme Court case McCulloch, Chairman, National Labor Relations Board (NLRB), et al. v. Sociedad Nacional de Marineros de Honduras in 1962 centered around the jurisdiction of the NLRB over foreign-flag ships and their crews operating in American waters. The Honduran corporation Sociedad Nacional de Marineros operated a ship with an all-Honduran crew that was involved in commerce between New York and Puerto Rico - both U.S territories. A dispute arose when the company refused to bargain with a labor union representing its employees, leading to charges filed with the NLRB for unfair labor practices under Section 8(a)(5) of the National Labor Relations Act (NLRA). The Supreme Court ruled that applying NLRA's provisions on such foreign entities would infringe upon principles of international law and comity; thus it held that Congress did not intend for NLRA to apply here due to lack of explicit statutory language indicating so.

In the dissenting opinion for McCulloch v. Sociedad Nacional de Marineros de Honduras, Justice Hugo Black argued that the National Labor Relations Board (NLRB) did not have jurisdiction over labor disputes involving foreign-flag ships and their crews. He contended that extending NLRB authority to such cases would infringe on the sovereignty of other nations and potentially create international conflicts. Furthermore, he believed it was inappropriate for American courts to apply U.S. labor laws in situations where both parties involved were foreign entities operating outside U.S territory or waters - as was the case with this Honduran ship crewed by Hondurans but docked at an American port during a strike dispute between its owners and workers unionized under an American federation.