In the case of O'Keeffe, Deputy Commissioner, Sixth Compensation District, Department of Labor v. Aerojet-General Shipyards Inc., 1971, the U.S Supreme Court ruled in favor of Aerojet-General Shipyards. The issue at hand was whether a claim for disability benefits under the Longshoremen's and Harbor Workers' Compensation Act could be filed more than one year after an injury occurred if it wasn't immediately apparent that the injury would lead to disability. In this instance, a shipyard worker had injured his knee but did not file for compensation until over two years later when he became disabled as a result of complications from surgery on that same knee. The court held that since there was no way for him to have known about these potential future consequences at the time of his initial injury or surgery recovery period, he should still be allowed to file his claim even though it fell outside what is typically considered timely filing.

In the dissenting opinion for O'Keeffe v. Aerojet-General Shipyards, Inc., Justice Harlan argued that the majority's decision to reverse and remand the case back to lower courts was unnecessary and inappropriate. He believed that there was no need for further fact-finding or reconsideration of evidence as it had already been thoroughly examined by both a deputy commissioner and an appellate court, who found in favor of Aerojet-General Shipyards. According to him, this case did not present any novel legal issues nor involve any misinterpretations of law which would warrant such action from Supreme Court. Instead, he saw it as a straightforward application of existing laws on workers’ compensation where factual findings should be left undisturbed unless they are unsupported by substantial evidence or tainted with error of law - neither condition being met here according to him.