The U.S. Supreme Court case Panama Railroad Company v. Bosse in 1918 revolved around a dispute between the Panama Railroad Company and one of its employees, Mr. Bosse, who was injured while working on the railroad line located within the Canal Zone - an unincorporated territory of the United States at that time. The main issue under consideration was whether or not federal laws related to employers' liability were applicable in this zone despite it being outside mainland USA but still under American jurisdiction. The court ruled in favor of Mr. Bosse stating that Congress had intended for these laws to apply throughout all territories controlled by America including those beyond its continental borders like the Canal Zone where he worked when injured. This decision established a precedent confirming that federal employer liability laws do indeed extend to U.S.-controlled territories outside mainland USA thereby ensuring protection for workers employed there against workplace injuries without having their rights diminished due to geographical location.

In the dissenting opinion for Panama Railroad Company v. Bosse, Justice Holmes disagreed with the majority's interpretation of liability under maritime law. He argued that a ship owner should not be held liable for damages caused by an independent contractor unless it can be proven that they were negligent in their selection or supervision of said contractor. In this case, he believed there was no evidence to suggest negligence on part of the railroad company in hiring and supervising its contractors who loaded cargo onto ships at sea. Therefore, according to him, the railroad company should not have been held responsible for injuries sustained by a worker during loading operations carried out by an independent contractor.