In the case of United States v. New York and Cuba Mail Steamship Company, 1905, the U.S Supreme Court ruled on whether a ship owner could be held liable for damages caused by an accident that occurred due to negligence of its employees. The steamship company was sued after one of its vessels collided with another vessel in New York Harbor causing significant damage. The court found that under maritime law, a ship owner is not responsible for accidents caused by navigational errors made by their crew members while performing their duties unless it can be proven that there was fault or neglect on part of the shipowner in hiring incompetent officers. This ruling established important precedent regarding liability in maritime law cases involving collisions at sea.

In the dissenting opinion for United States v. New York and Cuba Mail Steamship Company, Justice Harlan argued that the majority's interpretation of the law was incorrect. He believed that Congress intended to impose a penalty on ship owners who failed to provide proper accommodations for their crew members, regardless of whether or not those crew members were American citizens. The majority had ruled otherwise, stating that only ships with American crews were subject to this law. Justice Harlan disagreed with this narrow interpretation and felt it undermined Congress' intent to ensure decent living conditions for all seamen aboard U.S.-flagged vessels. Furthermore, he expressed concern about potential negative impacts on international relations if foreign sailors were treated differently than their American counterparts while working on U.S.-registered ships.