The Ship Octavia was a case heard before the United States Supreme Court in 1816. The claimants, Nicholls et al., were seeking compensation for damages to their ship caused by an American vessel during the War of 1812. They argued that they had been wrongfully denied indemnification from Congress and requested payment for their losses. The court found that while Congress did not have a duty to pay out such claims, it could do so if it chose to exercise its power under Article I Section 8 of the Constitution which grants them authority over war-related matters. Ultimately, however, the court held that since there was no specific law authorizing payment for these types of claims at this time, Congress had not acted unlawfully in denying them compensation and thus dismissed their claim without prejudice.

In the case of The Ship Octavia, Nicholls et al., Claimants, a majority opinion was issued by the US Supreme Court. However, Justice Story dissented from this opinion. He argued that although it is true that under maritime law salvage services are to be rewarded with a portion of the salvaged property's value, in this particular case there were no actual damages suffered by any party and therefore no reward should have been granted for salvage services rendered. Furthermore, he noted that while it may be customary to award such rewards even when there is no damage done or loss sustained as long as some service has been provided which benefits another person or entity; however in this instance none had actually occurred since all parties involved had already agreed on how much money would change hands prior to any work being performed on behalf of Nicholls et al.. Therefore Justice Story concluded that awarding them anything more than what they had previously agreed upon would amount to unjust enrichment at the expense of those who paid for their services.