The United States Supreme Court case, United States of America v. New York and Porto Rico Steamship Company in 1915 revolved around the issue of whether or not a steamship company could be held liable for damages to cargo caused by rats while at sea. The New York and Porto Rico Steamship Company had transported sugar from San Juan, Puerto Rico to New York City on behalf of the Compania Azucarera de Vega Baja when it was discovered that some bags were damaged due to rat infestation during transit. The U.S government sued on behalf of the sugar company claiming negligence by the steamship company for failing to maintain a rat-free ship which resulted in damage to cargo under their care. However, after careful consideration, the Supreme Court ruled in favor of the steamship company stating that they could not be held responsible as there was no evidence proving negligence on their part nor any contractual obligation specifying them maintaining a rat-free environment onboard.

In the dissenting opinion for the case of United States v. New York and Porto Rico Steamship Company, Justice Holmes disagreed with the majority's interpretation of a statute that required ships to provide "reasonable means of escape" in case of fire. He argued that this requirement should be interpreted broadly to include not just physical exits but also equipment like life preservers which could aid in escape from a burning ship. According to him, it was unreasonable for the court to interpret this law so narrowly as only requiring physical exits because such an interpretation did not fully protect passengers' safety during emergencies on board ships. Furthermore, he believed that Congress intended for these laws regulating maritime travel to prioritize passenger safety above all else when they were enacted.