In the case of Stewart v. Washington and Alaska Steamship Company, 1901, the U.S Supreme Court ruled in favor of the defendant, Washington and Alaska Steamship Company. The plaintiff, Mr. Stewart was a seaman on one of their ships who had contracted smallpox during his employment with them. He sued for damages claiming that he got infected due to negligence by his employer as they failed to provide him with a safe working environment by not vaccinating him against smallpox before embarking on a voyage where an outbreak occurred. The court held that it was not customary or required under maritime law for employers to vaccinate all employees before voyages at sea; therefore there was no breach in duty from part of the company towards its employee's health safety standards. Furthermore, it found no evidence suggesting that vaccination would have prevented Mr.Stewart from contracting smallpox given its nature and unpredictability.

In the dissenting opinion for Stewart v. Washington and Alaska Steamship Company, it was argued that the majority had misinterpreted maritime law in their ruling. The dissenting justices believed that a ship's crew should be considered seamen under maritime law, regardless of whether they were engaged in navigation or not at the time of an accident. They contended that this interpretation is consistent with both historical precedent and common sense understanding of what constitutes a 'seaman'. Furthermore, they disagreed with the majority's view on contributory negligence - arguing instead that even if Stewart was negligent to some degree, he should still be entitled to damages as long as his negligence did not exceed 50%. Finally, they expressed concern about potential negative implications for workers' rights arising from this decision – fearing it could set a dangerous precedent where employers are absolved from responsibility for ensuring safe working conditions onboard ships.