Law School Case Brief
Jerome B. Grubart v. Great Lakes Dredge & Dock Co - 513 U.S. 527, 115 S. Ct. 1043, 130 L. Ed. 2d 1024, 1995 U.S. LEXIS 1622
The exercise of federal admiralty jurisdiction does not result in the automatic displacement of state law. It is true that, with admiralty jurisdiction comes the application of substantive admiralty law. But, to characterize that as "federal rules of decision," is a destructive oversimplification of the highly intricate interplay of the States and the National Government in their regulation of maritime commerce. It is true that state law must yield to the needs of a uniform federal maritime law when the U.S. Supreme Court finds inroads on a harmonious system. But this limitation still leaves the States a wide scope.
A company working under contract with Petitioner city of Chicago, Illinois (Chicago), replaced pilings around the piers projecting into the Chicago River and supporting a bridge. After seven months after performing such work, an eddy formed in the river, which flowed through to flood buildings in Chicago. After the flood, many alleged victims brought actions in Illinois state court against the dredging company and Chicago, claiming that the dredging company was negligent. Thereafter, the dredging company, filed an action against Chicago and others, which invoked federal admiralty jurisdiction, seeking indemnity and contribution from Chicago. Upon Chicago's motion, the district court dismissed for lack of jurisdiction. The Undited States Court of Appeals for the Seventh Circuit reversed, concluding that the district court had admiralty jurisdiction over the dredging company's suit under the Limitation of Vessel Owner's Liability Act, 46 U.S.C.S. Appx. §§ 181 et seq. Chicago and others filed a petition for certiorari review.
Did the federal district court have admiralty jurisdiction in the tort liability action between the parties?
The United States Supreme Court affirmed the decision of the appellate court, holding that the admiralty jurisdiction applies and comsidered a two-part test under which a tort claim was required to satisfy conditions both of location and of connection with maritime activity. The court determined that the location part of the test was satisfied because the tort that allegedly occurred took place on navigable water. The maritime connection inquiry was met because the incident had a potentially disruptive impact on maritime commerce and the general character of the activity giving rise to the incident showed a substantial relationship to traditional maritime activity.
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