The Ludvig Holberg case in 1894 revolved around a dispute over maritime law. The owners of the Norwegian ship, Ludvig Holberg, filed a libel against the American schooner, George W. Wells for damages caused by collision at sea near New York Harbor. The District Court ruled in favor of the Norwegian vessel and held that it was not responsible for any part of the accident while ordering George W. Wells to pay $7,500 as compensation for damages incurred by Ludvig Holberg. However, on appeal to the Supreme Court, this decision was reversed based on evidence presented which showed that both vessels were equally at fault due to their failure to comply with statutory rules governing navigation under such circumstances. Therefore, each party had to bear its own loss without recourse from one another - an application of mutual fault doctrine or "divided damages rule". This ruling set a precedent in U.S maritime law where if two ships are found equally at fault in a collision; they share damage costs regardless of actual damage sustained.

In the dissenting opinion for The Ludvig Holberg case, Justice Brewer argued that the majority's decision to hold a ship liable for damages caused by its cargo was incorrect. He contended that it is not reasonable or justifiable to hold an inanimate object (the ship) responsible for actions taken by humans (loading and unloading of cargo). Furthermore, he disagreed with the majority's interpretation of maritime law, stating that such laws were designed to protect ships from liability rather than impose it upon them. He also expressed concern about the potential implications of this ruling on future cases involving shipping accidents and liabilities.