The U.S. Supreme Court case Newport News Shipbuilding & Dry Dock Co. v. Schauffler et al., 1937, revolved around the issue of whether a state could exercise its jurisdiction over an injury that occurred on navigable waters within the state's boundaries but was not connected to any maritime service or function. The plaintiff, an employee of Newport News Shipbuilding & Dry Dock Company, was injured while working on a floating dry dock in Virginia and sought compensation under Pennsylvania law where his employer had its principal place of business. The court ruled in favor of the defendant company stating that only federal laws apply to injuries occurring upon navigable waters even if they are within a state’s boundary unless it is related to some form of maritime service or employment which wasn't applicable here as per Longshoremen's Act (33 USC §903(a)). Therefore, Pennsylvania lacked jurisdiction over this matter.

The dissenting opinion in the case of Newport News Shipbuilding & Dry Dock Co. v. Schauffler et al., argued that the majority's decision to allow a state agency to enforce its own workers' compensation laws on federal enclaves was incorrect and inconsistent with previous rulings. The dissenters believed that this ruling undermined the authority of Congress over federal territories, as established by Article I, Section 8, Clause 17 of the Constitution. They contended that allowing states to exercise their jurisdiction within these areas would lead to confusion and conflict between state and federal law enforcement agencies. Furthermore, they pointed out inconsistencies in how different states might apply their laws within such territories which could result in unequal treatment for workers based on where they were injured rather than who employed them or what work they were performing at the time of injury.