In the case of Michalic v. Cleveland Tankers, Inc., 1960, the US Supreme Court ruled in favor of an injured seaman who sought damages for his injuries under general maritime law and maintenance and cure. The plaintiff, John Michalic had been injured while working aboard a ship owned by Cleveland Tankers, Inc. He filed suit seeking compensation for his injuries as well as maintenance and cure - a maritime doctrine that requires a shipowner to provide food, lodging, and medical services to seamen who fall ill or become injured during service. The defendant argued that since they had already paid some amount towards these expenses voluntarily before the lawsuit was initiated; therefore it should be deducted from any award granted by court later on. The Supreme Court disagreed with this argument stating that voluntary payments made prior to litigation do not absolve employers from their full obligations under maintenance and cure nor can they be used as set-offs against damage awards in personal injury suits brought under general maritime law.

In the dissenting opinion for Michalic v. Cleveland Tankers, Inc., it was argued that the majority's decision to allow a seaman to recover damages under both maintenance and cure as well as unseaworthiness doctrines is inconsistent with previous court rulings and maritime law principles. The dissent emphasized that these two remedies are distinct in nature; maintenance and cure pertains to an employer’s obligation to provide medical care until maximum recovery, while unseaworthiness refers to vessel conditions not fit for their intended purpose. It was contended that allowing double recovery undermines the balance of interests between employers and employees established by maritime law, potentially leading to excessive liability for shipowners. Furthermore, they expressed concern over potential misuse of this ruling by claimants seeking unjust enrichment through overlapping claims.