Southern Pacific Co. v. Jensen (US 1917)
Facts: Jensen was an employee of the Southern Pacific Company (SP). He was working on a ship when he broke his neck and died. SP objected to the award from the NY Workers’ Comp. Commission that was awarded to his remaining family, arguing the award violated Art. 3, § 2 of the Const., conferring admiralty to federal courts. NY SC upheld the award.
Holding: -P is liable to employees for on the job injuries under the Federal Employers’ Liability Act (FELA).
-As applied here, the Workmen’s Compensation Act (of NY) conflicts w/ the general maritime law under the Const.
-Everything about this case is maritime and w/i admiralty jurisdiction
-If NY can subject foreign ships coming into her ports to such obligations as those imposed by her compensation statute, other states may do likewise. The necessary consequence would be the destruction of the very uniformity in respect to maritime matters which the Const. was designed to establish, and freedom of navigation b/w states and w/ foreign countries would be seriously hampered and impeded
-The remedy of the Compensation Statute is unknown to common law, therefore is not allowed to be adjudicated by states under the saving to suitors clause
-Exclusive jurisdiction of all civil cases of admiralty and maritime jurisdiction is vested w/i the federal district courts
- Southern Pacific Co. v. Jensen, 244 U.S. 205 (1917)
- FACTS: Respondent’s decedent was a worker at a pier where the petitioner’s ship was docked. The decedent’s job was to load the ship with lumbar. He was killed while performing his job. Respondent filed a workers’ compensation claim against the petitioner in NY state court for wrongful death benefits for her deceased husband.
- ISSUE: Is the NY workers’ compensation statute preempted by the federal admiralty law?
- HELD: The state workers’ compensation statute is unconstitutional to the extent that it conflicts with the Constitutional grant of admiralty jurisdiction to the federal system.
REASONING: The work
of a stevedore is maritime in nature; his employment was a maritime
contact; the injuries which were received were maritime; the rights and
liabilities of the parties in connection therewith were matters clearly
within the admiralty jurisdiction. The remedy given by the statute is
unknown to the common law and is not saved to suitors from the grant of
- Justice Holmes, dissenting: the remedy that is available is created by the NY common law. The mode of obtaining the remedy is what is different. This does not make the NY workers’ compensation statute incompatible with admiralty jurisdiction. The maritime law is not a corpus juris – it is a very limited body of customs and ordinances of the sea. The common law must be allowed to supplement the maritime law.
- Significance of the case: this was the first case where the Supreme Court held that Art. III, § 2 provided jurisdiction and the power to create admiralty law.
- Key language for determining whether federal maritime law preempts: if the claim is maritime, if there is a federal statute or a need for a federal common law rule to promote maritime shipping and commerce, then state law is preempted.