S. Pac. Co. v. Jensen - 244 U.S. 205, 37 S. Ct. 524 (1917)

Rule:

The Workmen's Compensation Act of New York conflicts with the general maritime law, which constitutes an integral part of the federal law under U.S. Const. art. III, § 2, and to that extent is invalid.

Facts:

An employee was killed while unloading lumber from a ship owned by employer, a railroad company. The employee's family filed a claim for death benefits under the Workmen's Compensation Act of New York (Act). The claim was approved and employer sought review. On appeal, employer argued that the Act did not apply because employee was engaged in interstate commerce on board a vessel of a foreign corporation of a state other than New York, and the Act was unconstitutional. The appellate court found that the Act did apply to employer and employee's family's claim, and affirmed the award. Employer again sought review.

Issue:

Was the Act unconstitutional? 

Answer:

Yes.

Conclusion:

The Court held that the remedy of the Act (it provides compensation upon a prescribed scale for injuries and deaths of employees, without regard to fault, to be administered and awarded primarily through a state administrative commission), is a remedy unknown to the common law and incapable of enforcement by the ordinary processes of any court, and hence is not among the common-law remedies which are saved to suitors from the exclusive admiralty jurisdiction by Judiciary Act of 1789, § 9; Judicial Code, §§ 24, 256. The remedy of the Act is inconsistent with the policy of Congress to encourage investments in ships, manifested by the Acts of 1851 and 1884 (Rev. Stats., §§ 4283-4285; c. 121, 23 Stat. 57), which declare a limitation upon the liability of their owners.