The U.S. Supreme Court case United States v. Nederlandsch-Amerikaansche Stoomvaart Maatschappij (Holland-America Lijn) in 1920 revolved around the issue of whether or not a ship owner could be held liable for damages caused by a collision with another vessel due to negligence on part of its captain, despite the fact that the owner had no knowledge or control over such actions. The Holland-America Line was sued by the U.S government after one of their ships collided with and damaged an American naval vessel during World War I. The court ruled in favor of the United States, stating that under maritime law, ship owners are responsible for any damage caused by their vessels regardless if they were aware or had direct control over those actions leading to damage.

The dissenting opinion in the case of United States v. Nederlandsch-Amerikaansche Stoomvaart Maatschappij (Holland-America Lijn) argued that the majority's decision to uphold a fine against Holland-America Line for violating immigration laws was incorrect. The dissenters believed that the company should not be held responsible for unknowingly transporting an immigrant who had been previously deported from America, as they were unaware of his status and had no reasonable means to discover it. They pointed out that there was no evidence suggesting any negligence or intentional wrongdoing on part of Holland-America Line, making it unfair to impose such a heavy penalty on them. Furthermore, they contended that this ruling could have serious implications for shipping companies worldwide and potentially disrupt international commerce by placing an undue burden on carriers to verify their passengers' immigration statuses.