The Standard Dredging Corporation v. Murphy case in 1942 revolved around a dispute over workers' compensation for an employee who was injured while working on a dredge outside of New York's territorial waters. The Supreme Court ruled that the state of New York could not extend its Workers' Compensation Law to cover injuries sustained by employees beyond the state's jurisdiction, even if their employment contract was made within the state and they were temporarily assigned elsewhere. In this specific case, it meant that Standard Dredging Corporation did not have to pay workers’ compensation under New York law for an injury occurring off the coast of Massachusetts. This decision emphasized states cannot apply their laws extraterritorially unless explicitly authorized by Congress.

In the dissenting opinion for Standard Dredging Corporation v. Murphy, Justice Frankfurter disagreed with the majority's interpretation of jurisdiction under the Longshoremen's and Harbor Workers' Compensation Act (LHWCA). He argued that Congress intended to cover all injuries occurring on navigable waters, regardless of whether they were caused by a vessel in navigation or not. The majority’s decision to exclude certain maritime workers from coverage based on their employment status was inconsistent with this intent. Furthermore, he contended that it was inappropriate for the Court to make determinations about which workers should be covered under LHWCA as these decisions should be left up to Congress. Finally, he expressed concern that this ruling would create confusion and uncertainty among lower courts trying to apply it in future cases.