Kossick v. United Fruit Co. - 365 U.S. 731, 81 S. Ct. 886 (1961)

Rule:

The fact that maritime law is--in a special sense at least, federal law and therefore supreme by virtue of U.S. Const. art. VI, carries with it the implication that wherever a maritime interest is involved, no matter how slight or marginal, it must displace a local interest, no matter how pressing and significant.

Facts:

In a diversity-of-citizenship suit in a Federal District Court in New York by petitioner, a seaman, against respondent, a shipowner, the complaint alleged that while a member of the crew of respondent's vessel, petitioner suffered an ailment which was not attributable to any fault of respondent but which entitled him to maintenance and cure. Petitioner requested private treatment at respondent's expense. Respondent denied petitioner’s request but promised that, if petitioner would accept treatment at a Public Health Service Hospital, respondent would assume responsibility for all consequences of improper or inadequate treatment. Petitioner did so and suffered injury as a result of improper treatment. The District Court dismissed the complaint, because it failed to allege that the agreement was in writing and such a verbal agreement is void under the New York Statute of Frauds. Petitioner sought review of the decision. 

Issue:

Under the circumstances, was it proper to apply the New York's Statute of Frauds to bar proof of the parties’ purported agreement? 

Answer:

No.

Conclusion:

On certiorari review, the United States Supreme Court held it was error to apply New York's Statute of Frauds to bar proof of purported agreement because maritime law, which validated oral contracts, controlled parties' dispute. The Court held that federal law, supreme by virtue of U.S. Const. art. VI, carried with it the implication that wherever a maritime interest was involved, that interest displaced a local interest no matter how significant. Further, because petitioner's cause was based on a contract dispute under which obligations were voluntarily undertaken, as opposed to the application of tort liability or public regulations, a presumption existed to apply that law tending toward the validation of an alleged contract. Finally, because of the nature of the contract, the Court held that the contract should be judged by one uniform law wherever it was made.