Chelentis v. Luckenbach S.S. Co. - 247 U.S. 372, 38 S. Ct. 501 (1918)

Rule:

Section 9 of the Judiciary Act of 1789, 1 Stat. 76, 77, gives no authority to the several States to enact legislation which would work material prejudice to the characteristic features of the general maritime law or interfere with the proper harmony and uniformity of that law in its international and interstate relations. That clause only saves to suitors the right of a common-law remedy, where the common law is competent to give it. It is not a remedy in the common-law courts which is saved, but a common-law remedy. A proceeding in rem, as used in the admiralty courts, is not a remedy afforded by the common law; it is a proceeding under the civil law.

Facts:

Petitioner seaman was injured while performing his duties on board the steamship "J. L. Luckenbach" operated and controlled by respondent. Petitioner instituted a common law action against respondent, demanding full indemnity for damage sustained. Petitioner claimed that his injuries resulted from the negligence and an improvident order of a superior officer. The court directed verdict for respondent, and judgment thereon was affirmed by the Circuit Court of Appeals. Petitioner appealed, arguing that he was not limited to maritime law damages for wages, maintenance, and cure. Petitioner argued that Congress changed the law limiting his right to recovery under maritime law by enacting § 20 of the Seamen's Act, c. 153, 38 Stat. 1164, 1185. He argued that the act made the master a fellow servant of the seaman and therefore that Congress intended to make the relation between the seaman and all the officers throughout the same as at common law.

Issue:

Was the petitioner seaman entitled to a full indemnity for damages sustained because of the enactment of § 20 of the Seamen's Act? 

Answer:

No.

Conclusion:

The court disagreed with the petitioner’s contentions, and held that § 20 of the Seamen's Act was not intended to substitute the rule of common law negligence for the maritime law of maintenance and cure. The plaintiff was engaged in maritime work, under a maritime contract, and his injuries were maritime in nature. He was only entitled to wages, maintenance, and cure, pursuant to maritime law, but he had not requested such relief. Additionally, Section 9 of the Judiciary Act of 1789, 1 Stat. 76, 77, the "savings clause," did not grant plaintiff the right to elect to have the shipowner's liability determined by common-law negligence standards.