In the case of Victory Carriers, Inc. v. Law (1971), the U.S. Supreme Court ruled that a longshoreman injured while working on a ship in navigable waters could not sue his employer under maritime law if he was covered by workers' compensation insurance as per the Longshoremen's and Harbor Workers' Compensation Act (LHWCA). The plaintiff, Mr. Law, had been injured when he slipped on an icy gangplank while loading cargo onto a ship owned by Victory Carriers, Inc., and sought to recover damages from his employer under general maritime law for negligence rather than through workers’ compensation benefits provided by LHWCA. However, the court held that since Mr. Law’s injury occurred during land-based activity within the scope of LHWCA coverage; it precluded any recovery under general maritime jurisdiction.

In the dissenting opinion for Victory Carriers, Inc. v. Law, Justice Blackmun argued that the majority's decision to deny a longshoreman's claim under the Jones Act was incorrect and overly narrow in its interpretation of maritime employment. He contended that while Mr. Law may not have been on navigable waters at the time of his injury, he was still performing duties essential to his employer’s ship loading operation which should qualify him as a seaman under this act. Furthermore, Justice Blackmun criticized the majority for their reliance on an outdated precedent set by Swanson v Marra Bros., asserting it failed to consider changes in modern shipping practices where much work traditionally done aboard ships is now performed ashore due to technological advancements and efficiency improvements.