In the 1923 case of St. Johns N.F. Shipping Corporation v. S.A Companhia Geral Commercial do Rio de Janeiro, the U.S Supreme Court was tasked with determining whether a ship owner could limit their liability for damages caused by negligence or misconduct of its captain and crew under American law, even when such limitation is not recognized in foreign jurisdictions where an incident occurred. The court ruled that while American law does allow ship owners to limit their liability in certain circumstances, this protection cannot be extended to incidents occurring in foreign waters if those countries' laws don't recognize such limitations on liability. In other words, U.S maritime law couldn’t shield a vessel's owner from full financial responsibility for damage done abroad if local laws held them fully accountable.

In the dissenting opinion for the case of St. Johns N.F. Shipping Corporation v. S.A Companhia Geral Commercial do Rio de Janeiro, Justice Holmes argued that the majority's decision to hold a ship owner liable for damages caused by an independent contractor was unjustified and inconsistent with established legal principles. He contended that under common law, a person who hires an independent contractor is not responsible for any negligence on part of the contractor unless it involves inherently dangerous activities or if there is failure in supervising properly which wasn't applicable here as per him. Therefore, he believed that St Johns should not be held accountable for damages caused by Companhia Geral's negligent loading of cargo onto its vessel since they were acting as independent contractors at their own discretion and risk.