In the 1934 case of Schnell et al. v. The Vallescura, the U.S Supreme Court ruled in favor of a ship's captain who had been sued by two passengers for breach of contract and false imprisonment. The plaintiffs were denied entry into Cuba due to immigration restrictions and were subsequently returned to New York on the same vessel they arrived on, as per Cuban law at that time. They claimed that their return passage was not part of their original agreement with the shipping company and thus constituted false imprisonment. However, Justice Cardozo stated that it is an implied term in every contract for sea travel that if admission is refused at destination because permission has been withdrawn or denied by public authority, there will be a duty upon the carrier to bring back his passenger safely where he came from unless some other disposition is made through mutual consent.

In the dissenting opinion for Schnell et al. v. The Vallescura, it was argued that the majority's decision to hold the ship owners liable for damages due to a breach of contract was incorrect. The dissenting justices believed that there had been no violation of contractual obligations by the ship owners as they were not responsible for unforeseen circumstances which led to delays in delivery and subsequent financial losses incurred by cargo owners. They contended that such risks are inherent in maritime transport and should be borne by those who engage in such ventures rather than being shifted onto others who have little control over them, like shipowners or carriers. Furthermore, they disagreed with the majority's interpretation of "readiness" under charter party agreements, arguing instead that readiness should be understood within reasonable limits given practical realities faced at sea.