In the Saltonstall v. Birtwell case of 1893, the United States Supreme Court ruled on a dispute involving maritime law and insurance claims. The plaintiff, Saltonstall, was an underwriter for a ship that had been damaged in transit from New York to San Francisco via Cape Horn. He sued Birtwell, who was responsible for loading the cargo onto the ship before its departure. Saltonstall claimed that Birtwell's negligence in stowing caused damage to both vessel and cargo during rough seas encountered en route. The court held that while there were damages due to poor stowage of some parts of cargo by stevedores (Birtwell), it could not be proven beyond doubt whether this directly led to all subsequent damages suffered by other parts of vessel or cargo during voyage due to heavy weather conditions at sea. Therefore, despite acknowledging partial liability on part of defendant (Birtwell) towards plaintiff (Saltonstall), court did not find him fully liable for all losses incurred as causation could not be conclusively established between his negligent act and total extent of loss/damage sustained.

In the dissenting opinion for Saltonstall v. Birtwell, it was argued that the plaintiff should have been allowed to recover damages from a federal officer who had allegedly violated his rights under state law. The dissenting justices believed that federal officers were not immune from liability for their actions simply because they were acting in an official capacity. They asserted that if a federal officer violates someone's rights under state law, then they should be held accountable just like any other citizen would be. This perspective emphasized individual accountability and responsibility over blanket immunity for government officials, suggesting that no one is above the law regardless of their position or status.