The Frances, Boyer, Master case was a dispute between the owners of two vessels over damages caused by one vessel to another. The Supreme Court held that the owner of the damaged vessel had a right to recover from the other for any damage done in consequence of its negligence or wantonness. The court also found that when an injury is committed through gross negligence or willful misconduct, it may be considered as evidence of malice and therefore can be punished with exemplary damages. Furthermore, if there is no proof that actual malice existed at the time of injury then only nominal damages should be awarded. Finally, where there are multiple defendants involved in causing an injury they must all contribute equally towards compensating for such injuries regardless whether their individual acts were negligent or not.

In the case of The Frances, Boyer, Master (Dunham and Randolph's Claim), the dissenting opinion was that a master should not be held liable for damages caused by his vessel. The majority had ruled that since Dunham and Randolph were in possession of the ship at the time it sustained damage, they could recover from its master. However, Justice Johnson argued that this would lead to an unjust result as masters are generally not responsible for such losses unless there is evidence of negligence or misconduct on their part. He further noted that if Dunham and Randolph were allowed to recover from the master without any proof of fault then all other owners who have suffered similar losses would also be able to do so - leading to an unfair burden being placed upon them. Ultimately he concluded that while Dunham and Randolph may have been wronged in some way due to their loss, it was not appropriate for them to seek recovery from someone who had no responsibility over what happened.