The Max Morris case in 1890 involved a dispute over the seizure of a vessel, The Max Morris, by the United States government. The ship was seized under suspicion that it had been outfitted for seal hunting in violation of U.S. law prohibiting such activities without proper licensing and regulation. However, the claimant, Mr. Morris argued that at no point did his vessel engage in illegal sealing operations nor did he have any intention to do so; rather he claimed his intent was to use the ship for general trading purposes only. The Supreme Court ruled against Mr. Morris stating that there was sufficient evidence indicating an intent to engage in illegal sealing activity based on various equipment found aboard including guns and ammunition specifically designed for seal hunting as well as large quantities of salt used for preserving pelts which were not typically carried by vessels engaged solely in trade activities. This ruling established precedent regarding interpretation of "intent" within maritime law: even if an alleged crime has not yet occurred or is never committed, possession or preparation with specific tools can be enough proof to establish criminal intent.

In the dissenting opinion for The Max Morris: Morris, Claimant case in 1890, Justice Lamar disagreed with the majority's ruling that a ship owner could be held liable for damages caused by his vessel while under charter to another party. He argued that when a ship is chartered out, it becomes an extension of the business of the charterer and thus any liability should fall on them. According to him, holding owners responsible would create an undue burden on commerce as they cannot control or foresee actions taken by independent contractors such as charterers. Furthermore, he pointed out inconsistencies in applying this principle only to maritime law but not other areas where property is leased or rented. Thus, he believed that responsibility should lie with those who have direct control over operations rather than distant owners.