In the 1926 case of Steamship Willdomino v. Citro Chemical Company, the U.S Supreme Court was tasked with determining liability for damages incurred when a steamship owned by the plaintiff collided with a sunken barge owned by the defendant. The collision occurred in New York Harbor during foggy conditions and resulted in significant damage to both vessels. The lower court had ruled that both parties were equally at fault due to their failure to adhere to navigation rules designed for such weather conditions, thereby dividing responsibility for damages evenly between them. However, upon appeal, this decision was reversed by the Supreme Court which held that while both parties may have been negligent in their adherence to navigational procedures, it could not be definitively established that these failures directly contributed or caused the accident itself. Therefore, according to maritime law principles of "in extremis" (meaning 'at point of death' or 'under extreme circumstances'), where actions taken under emergency situations are judged differently than those made under normal circumstances - it was determined that only Citro Chemical Company's negligence led directly and proximately caused harm; thus they were solely liable for all resulting damages.

The dissenting opinion in the case of Steamship Willdomino v. Citro Chemical Company disagreed with the majority's ruling that a ship owner could not be held liable for damages caused by an independent contractor. The dissent argued that, under maritime law, a ship owner should bear responsibility for any damage done to cargo while it is under their care and control, regardless of whether they personally caused the damage or if it was due to negligence on part of an independent contractor hired by them. They contended that this principle is fundamental to maritime commerce as it ensures protection for shippers who entrust their goods to carriers without having any say in how those carriers choose to handle or store the cargo onboard. Therefore, according to this view, absolving ship owners from liability would undermine confidence in maritime trade and disrupt commercial relationships.