In the 1895 Supreme Court case, The Eliza Line, a dispute arose over maritime law and salvage rights. A British ship named "The Eliza" was stranded on the coast of Washington State during a storm. An American vessel called "The Favorite" rescued it and claimed salvage rights to its cargo as compensation for their efforts. However, the owners of The Eliza argued that they were not entitled to such rewards because they had already contracted with another company for rescue services before The Favorite intervened. They also contended that since both ships were foreign vessels in U.S waters at the time of incident, U.S courts did not have jurisdiction over this matter. However, after reviewing international laws and treaties regarding maritime disputes between foreign entities within domestic waters, the Supreme Court ruled in favor of The Favorite's crew members stating that they indeed had valid claims to salvage rights under existing laws due to their successful rescue operation regardless of any prior agreements made by The Eliza's owners with other parties. Furthermore, it held that U.S courts do have jurisdiction over such cases involving foreign vessels if incidents occur within its territorial boundaries.

In the dissenting opinion for The Eliza Line case, Justice Brewer argued that the majority's decision to hold a ship owner liable for damages caused by an independent contractor was incorrect. He contended that it contradicted established legal principles which generally absolve employers from liability for acts of independent contractors. According to him, this principle should apply even in cases where damage is done due to negligence on part of the contractor while performing tasks within their contract’s scope. He further opined that if any exception were made, it would be more appropriate in instances where there is inherent danger involved or when public safety might be compromised; neither of which he believed applied in this particular case involving a collision between two vessels at sea. Thus, he disagreed with imposing liability on ship owners who had no control over or participation in actions leading up to such accidents.