In the United States v. Vulte case of 1913, the Supreme Court ruled on a dispute regarding military pay. Lieutenant Commander J.H. Vulte was serving in the U.S Navy and claimed that he should receive higher compensation based on an act passed by Congress in 1908 which increased naval officers' salaries when at sea or foreign shore stations. The government disputed this claim, arguing that since Vulte's service was performed within continental limits of U.S., it did not qualify for additional pay under the terms of said act. The court sided with Lt. Cmdr. Vulte, stating that his service aboard a ship classified as "at sea," regardless if it is within territorial waters of U.S.. It further clarified that being "at sea" does not necessarily mean to be beyond three-mile limit (territorial waters), but rather refers to duty upon navigable waters whether they are inside or outside these boundaries. This ruling established important precedent for interpretation of laws concerning military pay and benefits, emphasizing broader understanding over literal interpretations.

In the dissenting opinion for United States v. Vulte, Justice Holmes disagreed with the majority's interpretation of a statute regarding military pay. He argued that Congress intended to provide additional compensation for officers serving beyond U.S borders, regardless of whether they were at sea or on land. The majority interpreted the law as only applying to those stationed at sea, but Holmes contended this was an overly narrow reading that did not align with Congressional intent. Furthermore, he suggested that if Congress had meant to limit extra pay in such a way, it would have explicitly stated so in the legislation itself.