In the case of Wilbur-Ellis Co. et al. v. Kuther, the U.S Supreme Court ruled in favor of a fish cannery worker who had been injured on the job and sought compensation under Alaska's Workmen's Compensation Act. The court held that even though he was not an American citizen or resident, but rather a temporary alien laborer from Canada, he was still entitled to benefits under this act because his employment contract with Wilbur-Ellis Company was made within the United States (Alaska). The company argued that since they paid him in Canadian currency and intended for him to return to Canada after his seasonal work ended, their relationship did not fall under Alaskan jurisdiction; however, this argument failed as it contradicted previous rulings which stated that where a contract is made determines its governing law.

In the dissenting opinion for Wilbur-Ellis Co. et al. v. Kuther, Justice Harlan disagreed with the majority's interpretation of Section 7 of the Clayton Act and its application to this case. He argued that a literal reading of Section 7 would not prohibit all acquisitions by corporations already engaged in commerce but only those that might substantially lessen competition or tend to create a monopoly within any line of commerce in any section of the country. In his view, there was no substantial evidence on record showing such an effect from Wilbur-Ellis' acquisition of Pacific Gamet Fish Company's assets; thus, he believed it should not be considered unlawful under Section 7 as interpreted by Congress and previous court decisions.