In the case of United States v. Hamburg-Amerikanische Packetfahrt-Actien Gesellschaft (1915), the U.S. Supreme Court ruled that a corporation could be held criminally liable for antitrust violations committed by its agents acting within their authority, even if those actions were against corporate policy or unknown to senior management. The defendant was a German shipping company accused of participating in an illegal monopoly on freight services between Puerto Rico and New York City through price-fixing agreements with other companies. Despite arguments that the offending actions were taken without knowledge or approval from upper management, the court upheld lower courts' rulings holding the corporation responsible for its employees' conduct while performing duties related to their employment.

In the dissenting opinion for the United States v. Hamburg-Amerikanische Packetfahrt-Actien Gesellschaft case, it was argued that the majority's decision to uphold a fine against Hamburg-American Steamship Line for its failure to maintain manifests of all cargo on board was unjustified. The dissenting justices believed that there were no clear legal guidelines or requirements at the time stating that such detailed manifests needed to be kept by shipping companies. They also pointed out inconsistencies in how similar cases had been handled previously, with some companies not being fined despite committing similar offenses. Furthermore, they expressed concern about potential negative impacts on international trade due to this ruling and emphasized their belief in upholding principles of fairness and consistency in law enforcement.