In the case of Strathearn Steamship Company, Limited v. Dillon (1919), the U.S. Supreme Court ruled in favor of a seaman who had been injured while working on a British ship that was docked in an American port at the time of his injury. The court held that despite being employed by a foreign company and serving aboard a foreign vessel, he was entitled to compensation under U.S law because his injury occurred within American jurisdiction. This ruling established an important precedent for maritime law: namely, that workers' rights are protected regardless of their nationality or employer's country if they are injured within U.S territory.

In the dissenting opinion for the case of Strathearn Steamship Company, Limited v. Dillon, Justice McReynolds disagreed with the majority's interpretation of The Seamen’s Act of 1915. He argued that it was not Congress' intention to give foreign seamen aboard foreign vessels rights to wages when they deserted their ship while in American ports. According to him, such an interpretation would interfere with international law and treaties which traditionally govern these matters between nations. Furthermore, he believed this could lead to diplomatic issues as other countries might view this as an overreach by U.S courts into their jurisdictional affairs concerning their own citizens on board their ships in foreign waters or ports.