In the 1953 case Voris, Deputy Commissioner v. Eikel et al., the U.S Supreme Court ruled on a dispute involving workers' compensation under the Longshoremen's and Harbor Workers' Compensation Act. The respondent, Southern Stevedoring & Contracting Co., had been ordered to pay disability benefits to an injured employee but argued that it should be reimbursed by its insurance carrier for these payments. However, because of a clause in their contract stating that no claim would be covered if not reported within one year of injury occurrence or knowledge thereof, the insurer refused reimbursement as they were notified after this period had lapsed. The court held that such contractual provisions could not limit an employer’s statutory right to recover from its insurer any compensation it was required by law to pay out under the act - regardless of when notice was given about potential claims.

In the dissenting opinion for Voris v. Eikel, Justice Douglas argued that the majority's decision was inconsistent with both previous case law and legislative intent. He contended that Congress had intended to provide compensation for all injuries sustained by workers on navigable waters in the course of their employment, regardless of whether they were caused by negligence or not. The majority's interpretation, he believed, would unfairly limit this coverage and leave many injured workers without recourse. Furthermore, he criticized the majority for relying on a distinction between 'contractual' and 'tortious' liability which he saw as irrelevant to the issue at hand - namely determining who should bear responsibility for workplace accidents occurring on navigable waters.