In the case of The Schooner Catharine, Her Tackle, &c., Starks W. Lewis and Others, Owners and Claimants v. Noah Dickinson and Others, Libellants (1854), the Supreme Court had to decide whether a contract between two parties was valid under maritime law or not. At issue was whether an agreement made by Starks W. Lewis for his vessel to be used in transporting goods from New York City to Philadelphia should be enforced as it did not include any specific terms regarding payment for services rendered nor did it specify when payment would be due upon completion of the voyage. The court ultimately ruled that such contracts are enforceable under maritime law if they contain sufficient evidence that both parties intended to enter into a binding agreement; however, since this particular contract lacked any details concerning compensation or timing of payments due upon completion of service delivery, it could not be enforced as written and thus must fail on its merits.

In the dissenting opinion of The Schooner Catharine, Her Tackle, &c., Starks W. Lewis and Others, Owners and Claimants v. Noah Dickinson and Others case, Justice McLean argued that the lower court's decision should be reversed because it was based on an erroneous interpretation of a federal statute regarding salvage claims for vessels wrecked in 1851. He noted that under this law any vessel which had been "wrecked" prior to December 31st of that year would not be eligible for salvage awards; however he argued that since the schooner Catharine had only been partially damaged by a storm at sea before being brought into port by her crew members who were attempting to save her from further destruction she did not qualify as having been "wrecked". Therefore he concluded that the owners were entitled to receive compensation for their losses due to their efforts in saving their vessel from complete destruction.