In the case of The United States v. Holland-American Line, 1914, the U.S. Supreme Court was tasked with determining whether or not a ship owner could be held liable for unpaid duties on goods that were lost during transit due to no fault of their own. The Holland-American Line had transported several shipments of sugar from Java to New York City between 1909 and 1910, but some of this cargo was damaged in transit and subsequently condemned by customs officials upon arrival in New York. Despite this loss, which occurred through no negligence on part of the shipping company itself, the government still sought payment for import duties on all original quantities shipped. The court ruled in favor of Holland-America line stating that under section 28b Act June 10th ,1890 (26 Stat at L.,140), as amended by section III Act July24th ,1897(30 Stat at L.,211,chap11) it is clear that duty cannot be collected upon merchandise which has been destroyed before its arrival within limits where inspection can take place.

In the dissenting opinion for The United States v. Holland-American Line, Justice Holmes disagreed with the majority's ruling that a ship owner could not be held liable for damages caused by rats on their vessel. He argued that under maritime law, ship owners are responsible for maintaining safe conditions aboard their vessels and should therefore be accountable if they fail to control vermin infestations which cause damage or harm. In his view, this responsibility extends beyond just ensuring physical safety but also includes preventing potential health hazards such as diseases carried by rats. Therefore, he believed that the Holland-American Line should have been found liable in this case.