In the 1961 case of Salem v. United States Lines Co., the Supreme Court ruled in favor of a seaman who had been injured while working on a ship owned by United States Lines Company. The plaintiff, Mr. Salem, was awarded damages for his injuries under the Jones Act which provides compensation to sailors for injuries suffered due to negligence by their employers. However, he also sought maintenance and cure - an ancient maritime doctrine that requires a shipowner to provide food, lodging (maintenance), and medical services (cure) until maximum recovery is achieved if a sailor falls ill or gets injured during service regardless of fault. The lower courts denied this claim arguing that since he had already received compensation under the Jones Act it constituted double recovery. The Supreme Court disagreed with this reasoning stating that these were two separate issues: one concerning negligence leading to injury; another about care owed after such injury occurs irrespective of how it happened or who was at fault as long as it occurred during service period on board ship. Therefore, they held that receiving damages under Jones Act did not preclude him from claiming maintenance and cure.

In the dissenting opinion for Salem v. United States Lines Co., it was argued that the majority's decision to allow a seaman to recover damages under general maritime law, despite having already received compensation under the Longshoremen's and Harbor Workers' Compensation Act (LHWCA), would lead to unjust double recovery. The dissenting justices believed this ruling contradicted previous decisions which held that an injured worker could not receive both statutory benefits and common-law damages simultaneously. They also expressed concern about potential negative impacts on employers who might face increased liability costs due to multiple claims from employees for a single injury, potentially leading them to reduce workforce or increase prices of goods and services in response. Furthermore, they disagreed with the majority’s interpretation of LHWCA as non-exclusive remedy arguing instead that Congress intended it as exclusive remedy for injuries occurring upon navigable waters of U.S., thus precluding any additional recovery under general maritime law.