Admiralty claim may proceed in state court, Supreme Court says.

The U.S. Supreme Court unanimously handed admiralty claimants a victory February 21 when it ruled that a seaman injured aboard a ship may sue the vessel owner in state court. (Lewis v. Lewis & Clark Marine, No. 99-1331, 2001 WL 167535 (U.S. Feb. 21, 2001).)

The claimant, James Lewis, worked as a deckhand aboard a ship. He claimed that a wire had been negligently left exposed on deck, causing him to trip and injure his back. He sued the shipowner under the Jones Act in an Illinois state court.

The defendant persuaded a federal district court to grant an injunction barring the filing of any state law claims related to the incident until the issue of limiting the defendant's liability was clarified. The company cited the federal Limitation of Liability Act, which grants shipowners the right to seek limitation of liability in federal court for claims of injuries that occur aboard their vessels. But the court dissolved that injunction, allowing the seaman to proceed in state court. The Eighth Circuit Court of Appeals later reversed that decision.

Reinstating the claim, the Supreme Court recognized that a section of the U.S. Code known as the "savings to suitors" clause was enacted to preserve common law remedies and concurrent state court jurisdiction over some admiralty and maritime claims. The existence of this clause indicates that Congress never intended the federal courts to have exclusive jurisdiction over all claims that arise in marine-related accidents, the justices said.

The appeals court erred, the Supreme Court found, when it concluded that because the plaintiff had not requested a jury trial, he had not reserved his right to proceed in state court. Claimants in such cases may seek remedies in state court regardless of whether they requested a jury trial, the Court decided.

The seaman in this case did several things, the Court said, that ensured preservation of the defendant's rights under the Limitation of Liability Act. He stated that he was the only claimant with respect to the incident, stipulated that the defendant could relitigate limited-liability issues in the federal district court, and declared that his claim's value was less than the value of the defendant's interest in the vessel.

Having satisfied itself that defendant's limitation rights would be protected, the district court acted well within its discretion in dissolving the injunction, the Court concluded.

Roy Dripps III, who won the case, said it is a significant victory for admiralty claimants because it "preserves their right to proceed in state court, rather than face a bench trial in a federal court before a judge who may not be receptive to these claims." Staying in state court may allow claimants to avoid the tougher evidentiary standards of Daubert v. Merrell Dow Pharmaceuticals, he added.