In the case of North American Transportation & Trading Company v. Morrison, 1899, the U.S Supreme Court was tasked with determining whether a contract made in Illinois but to be executed in Alaska could be enforced under Alaskan law. The dispute arose when James Morrison sued North American Transportation and Trading Company for breach of an employment contract that he claimed promised him a two-year term as superintendent at $300 per month plus expenses. The company argued that since the agreement was not written or signed by them, it did not constitute a binding contract under Illinois law which required such contracts to be in writing. The court ruled against Morrison stating that while oral agreements were enforceable under Alaskan law where the work was performed, they had to abide by Illinois laws where it originated from and thus needed to have been put into writing. This decision established precedent on how jurisdictional differences can affect contractual obligations.

In the dissenting opinion for North American Transportation & Trading Company v. Morrison, it was argued that the majority's decision to uphold a lower court ruling in favor of Morrison failed to adequately consider the unique circumstances and challenges faced by businesses operating in Alaska during this time period. The dissent emphasized that due to Alaska's harsh weather conditions and remote location, companies like North American Transportation & Trading were often forced to rely on third-party contractors who may not always fulfill their obligations as expected. Therefore, they believed it was unfair for such companies to be held fully liable when these unforeseen complications led them unable to meet their contractual commitments. They also disagreed with the majority’s interpretation of maritime law and contract law principles applied in this case.