- Garrett v. Moore-McCormack Co., Inc., 317 U.S. 239 (1942)
- FACTS: The Pwas injured during a voyage between the USA and Poland. He spent a significant amount of time in hospitals in Poland and the USA. There were questions of when/where the occurrence occurred and whether or not the Psigned a release in consideration of $100. The suit was brought by the Pin Pennsylvania state court.
- ISSUE: Does the Pennsylvania rule of requiring evidence beyond a reasonable doubt to support invalidation of a compromise agreement contradict admiralty rules?
- HELD: Under admiralty rules, the burden is upon one who sets up a seaman’s release to show that it was executed freely, without deception or coercion, and that it was made by the seaman with full understanding of his rights. The admiralty rule is inconsistent with the state rule, and therefore, Pennsylvania was bound to apply the admiralty rule.
- REASONING: In trying the case, the
state court was bound to proceed in such a manner than all the
substantial rights of the parties under the controlling federal law
would be protected. Congress has acted concerning seaman’s releases.
The fiduciary must show affirmatively that no advantage has been taken.
The right of the Pto be free of the burden of proof imposed by the
Pennsylvania court is inherent in his admiralty cause of action. The
court basically concluded that the burden of proof issue was substantive
and not procedural, so therefore, the Pennsylvania court could not
displace it with its own law.
- Significance: if the procedural rule in an admiralty action is an integral part of the substantive right, then the procedural rule must be applied in state court.
Questions to ask in analyzing a maritime issue:
- FIRST QUESTION: if you are going to lose under state law, is there a salty flavor? If you can make an argument that there is an admiralty claim, you can increase your settlement prospects? Is the case involved maritime in nature?
- SECOND QUESTION: If the case is maritime, is there a federal rule that applies to case, or is there no rule? If there is a federal rule established (by statute or common law) then it applies.If not, then we have to ask whether state law should be displaced and a federal rule should be established.
- THIRD QUESTION: Where is there jurisdiction? If there is a federal statute on the admiralty, then the case can be brought under § 1331 (fed ?); If the rule is based on federal common law, then it can be brought under § 1333 (admiralty) without regard to citizenship or amount in controversy. There is no jury trial under § 1333. A common law rule can also be brought under a diversity claim under § 1332. The claim can also be brought in state court because § 1333 has been interpreted to provide concurrent jurisdiction except for a few specific types of claims.
- FOURTH QUESTION: If brought in state court, what procedure applies? See Garrett.
Three requirements that must be met in order to have a maritime claim:
- (1) navigable waters;
- (2) a vessel;
- (3) a “maritime flavor.”
Garrett v. Moore-McCormack Co., Inc. (US 1942)
Facts: P injured while working as a seaman for D. Sued in PA state court pursuant to the Jones Act.
Holding: Petitioner employee was injured while working as a seaman on a vessel for respondent employer. The intermediate court affirmed a judgment in respondent's favor in the suit that petitioner filed under the Jones Act, 46 U.S.C.S. § 688. The Court reversed that judgment on appeal, finding that petitioner was entitled to the benefit of the full scope of his federally created rights. The Court found that the intermediate court wrongfully held petitioner to the state, rather than the applicable federal, standard of sustaining his challenge to the validity of a release that he signed. The Court reasoned that allowing the intermediate court to substantially alter petitioner's federally established rights was directly contrary to the congressional intent behind allowing it to hear cases under the Jones Act.
-P entitled to benefit of his federal rights even though this case was tried in PA court