In the 1894 Supreme Court case, The Caledonia, a British ship named "The Caledonia" was seized by an American revenue cutter off the coast of Alaska for illegally hunting seals in open waters. The owners of the vessel claimed that they were not aware of any laws or treaties prohibiting such activities and therefore should not be held accountable. However, it was determined that ignorance does not excuse violation of international law. Additionally, it was found that while there may have been no explicit treaty between Britain and America regarding seal hunting at this time, general principles of international law still applied to protect fur seals during their breeding season from being hunted in open sea. Therefore, the seizure was justified under U.S domestic legislation which gave effect to these principles - despite protests from Britain claiming extraterritorial enforcement. This ruling reinforced America's commitment to uphold its own laws as well as international agreements even when specific bilateral treaties did not exist.

In the dissenting opinion for The Caledonia case, it was argued that the majority had erred in their interpretation of maritime law. The dissenting justices believed that a ship's cargo should not be held liable for damages caused by the vessel unless there is evidence to suggest that those who owned or chartered the cargo were aware of and complicit in any negligence on part of the ship's crew. They contended that holding innocent parties responsible would set a dangerous precedent and could potentially disrupt international trade relations. Furthermore, they disagreed with how liability was apportioned among multiple parties involved in this case, arguing it unfairly burdened certain individuals while letting others off lightly.