In Tuten v. United States (1982), the Supreme Court ruled that a ship's crew members could not sue their employer, the federal government, for injuries sustained while on duty because they were covered by workers' compensation laws. The case arose when two seamen employed by the U.S. Army Corps of Engineers sought damages under general maritime law and the Jones Act after being injured aboard dredges in navigable waters. However, it was determined that these employees fell within an exception to this rule as they were "masters or members of a crew of any vessel." Therefore, their exclusive remedy was through workers’ compensation benefits provided under Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA). This decision clarified how different categories of maritime employees are treated under federal law.

In the dissenting opinion for Tuten v. United States, Justice Stevens argued that the majority's interpretation of a federal statute was incorrect and overly broad. He contended that Congress did not intend to make it a crime for seamen to abandon their vessel unless they were in military service or during times of war. According to him, this law was enacted primarily as an anti-mutiny measure rather than a general prohibition against desertion from commercial vessels under non-emergency circumstances. Furthermore, he pointed out that there are other legal remedies available if sailors breach their employment contracts by leaving ship prematurely such as civil damages or forfeiture of wages earned but unpaid at the time of desertion which should be sufficient deterrents without criminalizing such behavior.