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
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)
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?
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.
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).
I have often tried to make the cases available as links in case you are a student without a textbook.
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