Chelentis v. Luckenbach (US 1918)
Facts: Chelentis was aboard the Luckenbach as a fireman when a wave crashed onto the ship and broke his leg. He sued in NY demanding full indemnity for his injuries.
Holding: The seaman argued that he was not limited to maritime law damages for wages, maintenance, and cure. Claiming that his injuries resulted from the negligence of a superior officer, he filed a common law negligence suit in state court. The seaman 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. The court disagreed, holding that section 20 was not intended to substitute the rule of common law negligence for the maritime law of maintenance and cure. The seaman 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 seamen the right to elect to have the shipowner's liability determined by common-law negligence standards.
- Chelentis v. Luckenbach S.S. Co., Inc., 247 U.S. 372 (1918)
- FACTS: The petitioner was hired as a fireman aboard a vessel. He was injured at sea. He was given treatment on board the ship, and he was taken to the hospital upon return to shore. Ultimately the petitioner’s leg had to be amputated. The petitioner brought suit under NY law demanding full indemnity for the damages sustained. The case was removed to federal district court. The trial court entered a directed verdict for the respondent. The court of appeals affirmed.
- ISSUE: Does the admiralty law preclude the petitioner’s state law claim?
- HELD: The language of the admiralty statute discloses no intention to impose upon ship owners the same measure of liability for injuries suffered by the crew while at sea as the common law prescribes for employers in respect of their employees on shore.
- REASONING: The
petitioner’s work was maritime in nature. No state has the power to
abolish the well-recognized maritime rule concerning the measure of
recovery and substitute therefore the full indemnity rule of the common
law. There is nothing in the saving suitors clause which reveals an
intention to give the complaining party an election to determine whether
the defendant’s liability shall be measured by common-law standards
rather than those of the maritime law. Under the circumstances here
presented, the petitioner’s rights were those recognized by the law of
- Significance of seaman status: the seaman is entitled to a Jones Act claim, recovery for unseaworthiness and maintenance and cure.
- Significance of the case: if the case is maritime in nature, it doesn’t matter whether you bring the case in state or federal court, the admiralty law preempts the state common law.
- The “saving suitors clause” allows state courts to entertain in personam maritime causes of action; however, the extent to which state law may be used to remedy maritime injuries is limited in that substantive remedies afforded by state law must conform to governing federal maritime standards or at least they must not conflict with them.
- Conflicts between state law claims and admiralty claims when the occurrence involved is in state territorial waters must be resolved with a healthy regard for the needs of a uniform maritime law. Where (1) the unique state wrongful death act conflicts with two admiralty principles bearing directly on the rights of the parties (punitive damages and allocation of liability among joint tortfeasors); (2) the facts of the case are closely related to activity traditionally subject to admiralty law; and (3) the case falls under a federal statute, the Admiralty Extension Act, federal maritime law, and not state law, applies. In Re Amtrak “Sunset Limited” Train Crash, 121 F.3d 1421 (11th Cir. 1997).