The New York, 1899, is a US Supreme Court case that revolved around the issue of maritime law and liability. The steamship "New York" collided with another vessel in foggy conditions off the coast of New Jersey. Both vessels were damaged and there was loss of life on both sides. The owners of each ship sued for damages, blaming the other for not following proper precautions during low visibility conditions as required by maritime law. After lower courts ruled in favor of one party then reversed to rule in favor of the other, it reached the Supreme Court which held that both vessels were equally at fault because they failed to comply with statutory rules requiring them to slow down their speed under such circumstances. Therefore, according to established principles governing cases where both parties are at fault (the doctrine known as 'equal division'), each had to bear its own loss without recourse against the other.

In the dissenting opinion for The New York, 1899 case, Justice Harlan argued that the majority's decision was a misinterpretation of both constitutional law and precedent. He contended that Congress did not have unlimited power to regulate commerce between states and could only intervene when state laws interfered with interstate trade or were inconsistent with federal legislation. In this case, he believed there was no conflict between state and federal law as New Jersey’s regulation on oyster beds did not interfere with interstate commerce but merely regulated its own natural resources within its borders. Furthermore, he asserted that it is essential to preserve states' rights in order to maintain balance in our system of government. By allowing Congress such broad powers over commerce would undermine this balance by giving too much authority to the Federal Government at the expense of individual States’ sovereignty.