In the case of Pacific Mail Steamship Company v. Lucas, 1921, the U.S Supreme Court ruled in favor of Lucas. The dispute arose when a seaman named Lucas was injured while working on one of Pacific Mail's steamships and sought compensation for his injuries under federal maritime law. However, Pacific Mail argued that since the injury occurred within California state waters, it should be subject to state workers' compensation laws which would limit their liability significantly compared to federal maritime law. The court held that even though the injury occurred within three miles from shore (which is technically considered territorial waters), it was still covered by federal maritime jurisdiction as per previous rulings such as Southern Pacific Co v Jensen (1917). Therefore, they concluded that Lucas could seek damages under more generous federal laws rather than being limited by California’s worker’s compensation statute. This decision reinforced the principle that matters involving interstate commerce and navigation are generally governed by uniform national rules rather than individual state laws.

In the dissenting opinion for Pacific Mail Steamship Company v. Lucas, Justice Holmes disagreed with the majority's interpretation of The Seamen’s Act of 1915. He argued that while the act was designed to protect seamen from certain abuses by ship owners, it did not intend to completely absolve them of all responsibility or liability in cases where they were at fault. In this case, he believed that a sailor who had been injured due to his own negligence should not be entitled to full maintenance and cure under the law as interpreted by the majority. Instead, he suggested that such compensation should only apply when injuries occurred through no fault of their own or as a result of risks inherent in their work at sea.