Southern Pacific Company v. Jensen case brief summary
244 U.S. 205
CASE SYNOPSIS
Appellant employer sought review of an order from the Supreme Court, Appellate Division, Third Judicial Department of the State of New York, which held that the Workmen's Compensation Act of New York applied to appellee family of employee's claim, and approved a workmen's compensation claim following the work-related death of employee.
OVERVIEW: An employee was killed while unloading lumber from a ship owned by employer, a railroad company. The employee's family filed a claim for death benefits under the Act. The claim was approved and employer sought review. On appeal, employer argued that the Act did not apply because employee was engaged in interstate commerce on board a vessel of a foreign corporation of a state other then New York, and the Act was unconstitutional. The appellate court found that the Act did apply to employer and employee's family's claim, and affirmed the award. Employer again sought review.
HOLDING:
The Court held that the state legislature exceeded its authority in attempting to extend the Act to conditions such as employee's, that the Act's remedies were unknown to common law, that the remedies were incapable of enforcement by the ordinary processes of any court, and the remedies were not consistent with the policy of Congress to encourage investments in ships by declaring a limitation upon the liability of their owners.
ANALYSIS:
-As applied here, the Workman’s Compensation Act (of NY) conflicts with the general
maritime law under the Constitution.
-Everything about this case is maritime and within 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 Constitution was designed to establish, and freedom of navigation between states
and with 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
within the federal district courts.
OUTCOME: The Court reversed the award to employee's family because the Act was unconstitutional in that applied liability to foreign companies beyond the state legislature's authority and the Act's remedies were incapable to being enforced by courts and were contrary to Congress's attempt to encourage investments in ships by limiting ship owner's liability.
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244 U.S. 205
CASE SYNOPSIS
Appellant employer sought review of an order from the Supreme Court, Appellate Division, Third Judicial Department of the State of New York, which held that the Workmen's Compensation Act of New York applied to appellee family of employee's claim, and approved a workmen's compensation claim following the work-related death of employee.
OVERVIEW: An employee was killed while unloading lumber from a ship owned by employer, a railroad company. The employee's family filed a claim for death benefits under the Act. The claim was approved and employer sought review. On appeal, employer argued that the Act did not apply because employee was engaged in interstate commerce on board a vessel of a foreign corporation of a state other then New York, and the Act was unconstitutional. The appellate court found that the Act did apply to employer and employee's family's claim, and affirmed the award. Employer again sought review.
HOLDING:
The Court held that the state legislature exceeded its authority in attempting to extend the Act to conditions such as employee's, that the Act's remedies were unknown to common law, that the remedies were incapable of enforcement by the ordinary processes of any court, and the remedies were not consistent with the policy of Congress to encourage investments in ships by declaring a limitation upon the liability of their owners.
ANALYSIS:
-As applied here, the Workman’s Compensation Act (of NY) conflicts with the general
maritime law under the Constitution.
-Everything about this case is maritime and within 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 Constitution was designed to establish, and freedom of navigation between states
and with 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
within the federal district courts.
OUTCOME: The Court reversed the award to employee's family because the Act was unconstitutional in that applied liability to foreign companies beyond the state legislature's authority and the Act's remedies were incapable to being enforced by courts and were contrary to Congress's attempt to encourage investments in ships by limiting ship owner's liability.
---
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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