HomeSupreme Court Admiralty Cases1990-1999

The following are digests and links to Supreme Court opinions concerning admiralty and maritime law issued during the period 1990 through 1999. 

1990 - 1991 - 1994 - 1995 - 1996 - 1997 - 1998


Wright v. Universal Maritime Service Co., 525 U.S. 70 (1998)
Labor Law: the relevant collective bargaining agreement's general arbitration clause does not require longshoreman Wright to use the arbitration procedure for an alleged violation of the Americans with Disabilities Act of 1990.

Dooley v. Korean Air Lines Co., 524 U.S. 116 (1998)
Death on the High Seas Act ("DOHSA"): since Congress has chosen not to authorize a survival action for a decedent's pre-death pain and suffering in a case of death on the high seas, there can be no general maritime survival action for such damages.

California v. Deep Sea Research, Inc., 523 U.S. 491 (1998)
Admiralty Jurisdiction/Procedure (State Sovereign Immunity): the Eleventh Amendment does not bar a federal court's jurisdiction over an in rem admiralty action where the res is not within the State's possession; Abandoned Shipwreck Act ("ASA"): since the the lower courts' conclusion that the vessel was not abandoned for ASA purposes was influenced by the assumption that the Eleventh Amendment was relevant to the courts' inquiry, the case is remanded for reconsideration of the abandonment issue, with the clarification that the meaning of "abandoned" under the ASA conforms with its meaning under admiralty law.

Saratoga Fishing Co. v. J. M. Martinac & Co., 520 U.S. 875 (1997)
Products Liability: East River S. S. Corp. v. Transamerica Delaval Inc., 476 U.S. 858, held that an admiralty tort plaintiff cannot recover for the physical damage a defective product causes to the "product itself," but can recover for physical damage the product causes to "other property"; equipment added to the vessel in this case by the initial owner before he sold the vessel is "other property," not part of the product that itself caused physical harm, thus the present owner can recover for damage to the added equipment.

Harbor Tug & Barge Co. v. Papai Et Ux., 520 U.S. 548 (1997)
Jones Act: an important part of the test for determining who is a seaman is whether the injured worker has a substantial connection to a vessel or to a fleet of vessels, and the latter concept requires a requisite degree of common ownership or control; the requisite link is not established by the mere use of the same hiring hall which draws from the same pool of employees when the various vessels on which Plaintiff worked through the hiring hall were not linked by any common ownership or control.

Henderson v. United States,  517 U.S. 654 (1996)
Suits in Admiralty Act: the Suits in Admiralty Act's "forthwith" instruction for service of process has been superseded by Rule 4 of the Federal Rules of Civil Procedure, which sets an extendable 120 day period for service of process.

Exxon Co., U.S.A. v. Sofec, Inc.,  516 U.S. 1156 (1996)
Proximate Cause (Superseding Cause): a plaintiff in admiralty that is the superseding, and thus the sole proximate, cause of its own injury cannot recover part of its damages under the comparative fault principle of United States v. Reliable Transfer, 421 U.S. 397, from tort feasors or contracting partners whose blameworthy actions or breaches were causes in fact of the plaintiff's injury.

Zicherman v. Korean Airlines Co. Ltd., 516 U.S. 217 (1996)
Death on the High Seas Act ("DOHSA"): in a suit brought under Article 17 of the Warsaw Convention, a plaintiff may not recover loss of society damages for the death of a relative in a plane crash on the high seas, within the meaning of DOHSA.

Yamaha Motor Corp., U. S. A., v. Calhoun, 516 U.S. 199 (1996)
Wrongful Death: in maritime wrongful death cases in which no federal statute specifies the appropriate relief, and the decedent was not a seaman, longshore worker, or person otherwise engaged in a maritime trade, state remedies remain applicable and have not been displaced by the wrongful death action recognized in Moragne v. States Marine Lines, Inc., 398 U.S. 375.

Vimar Seguros y Reaseguros, S. A. v. M/V Sky Reefer, 515 U.S. 528 (1995)
Carriage of Goods by Sea Act ("COGSA"): COGSA does not nullify foreign arbitration clauses contained in maritime bills of lading.

Chandris, Inc. v. Latsis, 515 U.S. 347 (1995)
Jones Act: the "employment related connection to a vessel in navigation" necessary for seaman status comprises two basic elements: (1) the worker's duties must contribute to the function of the vessel or to the accomplishment of its mission and (2) the worker must have a connection to a vessel in navigation (or an identifiable group of vessels) that is substantial in both its duration and its nature. Jury Trials: whether a vessel is in navigation is a fact intensive question that can be removed from the jury's consideration only where the facts and the law will reasonably support one conclusion.

City of Milwaukee v. Cement Div., Nat'l Gypsum Co., 515 U.S. 189 (1995)
Procedure (Prejudgment Interest): neither a good faith dispute over liability nor the existence of mutual fault justifies the denial of prejudgment interest in an admiralty collision case. 

Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., 513 U.S. 527 (1995)
Admiralty Jurisdiction: the District Court had federal admiralty jurisdiction over Great Lakes's Limitation of Liability Act suit that arose from flooding on the Chicago River that resulted from damage to an underwater structure in the River caused by a construction barge, a vessel, that had driven piles into the river bed several months earlier. 

Howlett v. Birkdale Shipping Co., S. A., 512 U.S. 92 (1994)
Longshore & Harbor Workers' Act: a vessel's turnover duty to warn of latent defects in the cargo stow is narrow and attaches only to hazards that are not known to the stevedore and that would be neither obvious to, nor anticipated by, a skilled stevedore in the competent performance of its work.

McDermott, Inc. v. AmClyde, 511 U.S. 202 (1994)
Settlement Agreements/Damages: a nonsettling defendant's liability should be calculated with reference to the jury's allocation of proportionate responsibility, not by giving the nonsettling defendant credit for the dollar amount of the settlement.

American Dredging v. Miller, 510 U.S. 443 (1994)
Procedure (Forum Non Conveniens):in admiralty cases filed in state court under the Jones Act and the "saving to suitors clause," federal law does not pre-empt state law regarding the doctrine of forum non conveniens.

Exxon Corp. v. Central Gulf Lines, Inc., 500 U.S. 603 (1991)
Admiralty Jurisdiction: because there is no per se exception of agency contracts from admiralty jurisdiction, Minturn v. Maynard, 17 How. 477, in which an agent who had advanced funds for repairs and supplies necessary for a vessel was barred from bringing a claim in admiralty against the vessel's owners, is overruled; admiralty jurisdiction thus extends to Exxon's claim regarding the delivery of fuel in Jeddah where Exxon acted as Waterman's agent in procuring fuel from a local supplier; Maritime Liens: the Court expressed no view on whether Exxon was entitled to a maritime lien under the Federal Maritime Lien Act and left that issue to be decided on remand.

McDermott International, Inc. v. Wilander, 498 U.S. 337 (1991)
Jones Act: one need not aid in the navigation of a vessel in order to qualify as a "seaman" under the Jones Act.

Miles v. Apex Marine Corp., 498 U.S. 19 (1990)
Wrongful Death: the reasoning of Moragne v. States Marine Lines, Inc., 398 U.S. 375, which created a general maritime wrongful death cause of action, extends to suits for the death of true seamen despite the fact that Moragne involved a longshoreman, thus there is a general maritime cause of action for the wrongful death of a seaman; damages recoverable in a general maritime cause of action for the wrongful death of a seaman do not include loss of society; a general maritime survival action cannot include recovery for decedent's lost future earnings.

Sisson v. Ruby, 497 U.S. 358 (1990)
Admiralty Jurisdiction/Limitation of Liability Act: the District Court has jurisdiction over Sisson's limitation of liability action that arose from a fire aboard Sisson's pleasure yacht while it was docked at a Lake Michigan marina, destroying the yacht and damaging several neighboring vessels and the marina; admiralty jurisdiction is appropriate when a potential hazard to maritime commerce arises out of an activity that bears a substantial relationship to traditional maritime activity. 

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