In the case of Nolan, Administrator, et al. v. Transocean Air Lines in 1960, the Supreme Court ruled on a matter concerning wrongful death claims and jurisdictional issues. The plaintiffs were representatives of three deceased passengers who died in an airplane crash near San Francisco while en route from Hawaii to California. They filed suit against Transocean Air Lines under California's wrongful death statute which allowed for greater damages than those provided by federal law or Hawaiian law at that time. However, the airline argued that since it was operating under a contract with the U.S military and because the flight originated from Hawaii (a territory), only federal or Hawaiian laws should apply - both limiting potential damage awards compared to Californian law. The court had to decide whether state or federal jurisdiction applied when determining liability for deaths occurring over international waters but within close proximity to American soil.The Supreme Court held that where an injury occurs on navigable waters within a State's territorial limits but outside its internal boundaries (i.e., more than three miles offshore), maritime rather than local law applies unless Congress has indicated otherwise.

In the dissenting opinion for Nolan, Administrator, et al. v. Transocean Air Lines, Justice Frankfurter disagreed with the majority's interpretation of the Death on High Seas Act (DOHSA). He argued that DOHSA was not intended to be an exclusive remedy in cases involving wrongful death occurring more than a marine league from shore. Instead, he believed it should coexist with other remedies provided by state law or general maritime law unless there is a clear conflict between them. In this case, he saw no such conflict and therefore felt that California's wrongful death statute could apply concurrently with DOHSA. Furthermore, he criticized the majority for extending federal jurisdiction into areas traditionally governed by state law without explicit congressional authorization.