In the 1895 case Smith v. United States, the Supreme Court ruled on a matter involving maritime law and personal injury compensation. The plaintiff, Smith, was injured while working as a seaman on an American vessel in foreign waters. He sought damages from his employer under general maritime law for negligence and unseaworthiness of the ship. However, he had already received compensation through an administrative process established by Congress to provide quick relief for injured sailors without requiring them to sue their employers. The central question before the court was whether this statutory remedy precluded further recovery under general maritime law or if it merely provided an additional avenue of relief that did not limit other rights and remedies available to seamen. The Supreme Court held that when Congress provides a statutory remedy like this one, it does not eliminate any existing common-law rights unless it expressly says so; therefore Smith could seek additional damages under general maritime law despite having already received some compensation through the administrative process.

In the dissenting opinion for Smith v. United States, Justice Brewer argued that the majority's interpretation of the law was incorrect and overly broad. He contended that while Congress has power over territories, it does not have absolute authority to disregard constitutional protections in those areas. In his view, when a territory is acquired by the U.S., its inhabitants should be granted all rights under the Constitution immediately upon acquisition unless explicitly stated otherwise by Congress. This includes protection from cruel and unusual punishment as per Eighth Amendment rights which he believed were violated in this case due to excessive fines imposed on Smith for selling liquor without a license in Alaska Territory. The justice also disagreed with how territorial courts were established and operated outside of Article III judicial framework, arguing they should adhere strictly to federal laws rather than local customs or rules set up by military authorities during transitional periods after new territories are acquired.