In the case of Pillsbury et al., Deputy Commissioners, v. United Engineering Co. et al., 1951, the U.S Supreme Court was tasked with determining whether a ship repair company could be held liable for compensation under the Longshoremen's and Harbor Workers' Compensation Act (LHWCA) for injuries sustained by an employee while working on navigable waters but not aboard a vessel in navigation. The court ruled that such workers were indeed covered by LHWCA as long as their employment had some connection to maritime activity or commerce over navigable waters. This decision expanded protections for maritime workers and clarified that companies could be held responsible even if employees are injured off-ship but still within the scope of their maritime duties.

In the dissenting opinion for Pillsbury et al., Deputy Commissioners, v. United Engineering Co. et al., Justice Douglas argued that the majority's decision was a departure from established principles of statutory interpretation and administrative law. He contended that Congress had intended to provide compensation for all injuries sustained by employees in their employment, regardless of whether they were caused by negligence or not. The majority's ruling, he believed, undermined this intention by allowing employers to escape liability if they could prove that an employee's injury was due to his own willful misconduct or negligence. Furthermore, Justice Douglas criticized the majority for overruling the findings of fact made by an expert agency without sufficient justification and contrary to precedent which gives deference to such agencies' determinations unless clearly erroneous.