The Admiral Peoples - 295 U.S. 649, 55 S. Ct. 885 (1935)

Rule:

Admiralty jurisdiction in cases of tort depends upon the locality of the injury. It does not extend to injuries caused by a vessel to persons or property on the land. Where the cause of action arises upon the land, the state law is applicable.

Facts:

Petitioner was a passenger on the steamship "Admiral Peoples" on her voyage from Wilmington, California, to Portland, Oregon. While disembarking at Portland, petitioner was injured by falling from a gangplank leading from the vessel to the dock. Petitioner brought a libel in rem action against the ship, alleging that the ship was negligent in failing to provide a hand rope or railing at the end of the gangplank, in failing to have the plank flush with the dock or taper off to the level of the dock, and in failing to give warning of the step. The district court dismissed the action, sustaining the ship's exception to the libel on the ground that the action was not within the admiralty jurisdiction. The district court’s decision was affirmed by the appellate court. Writ of certiorari was granted. 

Issue:

Was the instant case within the jurisdiction of admiralty? 

Answer:

Yes.

Conclusion:

The court noted that the gangplank was a part of the vessel. It was a part of the vessel's equipment which was placed in position to enable its passengers to reach the shore. It was no less a part of the vessel because in its extension to the dock it projected over the land. Thus, while the libelant was on the gangplank she had not yet left the vessel. This was still true as she proceeded to the shore end of the plank. If while on that part of the vessel she had been hit by a swinging crane and had been precipitated upon the dock, the admiralty would have had jurisdiction of her claim. If instead of being struck in this way, the negligent handling of the vessel, as by a sudden movement, had caused her to fall from the gangplank, the cause of action would still have arisen on the vessel. The court perceived no basis for a sound distinction because her fall was due to negligence in the construction or placing of the gangplank. By reason of that neglect, as the libel alleged, petitioner fell from the plank and was violently thrown forward upon the dock. Neither the short distance that she fell nor the fact that she fell on the dock and not in the water, altered the nature of the cause of action which arose from the breach of duty owing to her while she was still on the ship and using its facility for disembarking. Consequently, the libel presented a case within the jurisdiction of admiralty.