Admiralty Jurisdiction in Tort Cases PDF

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Admiralty Jurisdiction in Tort Cases

Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., USSC, 1995 Facts: The city of Chicago hired the Great Lakes Dredge and Dock Company (“Great Lakes”) to perform work that would prevent ships from bumping into piers. Great Lakes used a crane to drive piles into the riverbed, which potentially weakened the structure of the freight tunnel that ran below the river. On April 13, 1992, water from the Chicago River poured into a freight tunnel which flooded into the basements of several buildings. After the flood, many victims sued Great Lakes in state court and argued that the flood was the result of the weakening of the tunnel. Great Lakes Dredge and Dock removed the case to federal district court and argued federal admiralty court had jurisdiction of marine cases. The district court dismissed the suit for lack of admiralty jurisdiction. The Seventh Circuit reversed. Issue: Whether a court of the United States has admiralty jurisdiction to determine and limit the extent of Great Lake’s tort liability Application: 

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The traditional test for admiralty tort jurisdiction rested upon whether the tort occurred on navigable water. If it did, admiralty jurisdiction followed and thus, the injury had to be “wholly” sustained on navigable waters. – Simple Locality Test The rule was changed in 1948 by Congress with the Extension of Admiralty Jurisdiction Act where jurisdiction extends to and includes cases of injury or damage, to persons or property, caused by a vessel on navigable waters, even though the injury or damage is done or consummated on land. Three cases from Supreme Court aimed at keeping different classes of odd cases out o Executive Jet Aviation, Inc. v. Cleveland where the Court held that an airplane accident that had to do with the collision of birds that led to the plane crashing in the navigable waters of Lake Erie would not be considered in an admiralty court to consider tort claims. The Court stated that an incident out of which a tort claim is considered must have had a disruptive influence on maritime commerce and have a substantial relationship in maritime activity. o Foremost Ins. Co. v. Richardson involved tort claims arising out of the collision of two pleasure boats in a navigable river estuary. There the court held that admiralty jurisidction did exist only if the “wrong” had a “significant connection with traditional maritime activity” where “the potential disruptive impact upon maritime commerce of a collision between boats on navigable waters, when coupled with the traditional concern that admiralty law holds for navigation” was included in the decision. o Sisson v. Ruby involved tort claims arising from a fire caused by a defective washer/dryer aboard a pleasure boat doecked at a marina. The fire burned the boat

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and other docks nearby and the marina itself. The Court held that a federal admiralty court did have tort jurisdiction because the fire, which burned docked boats at the marina on navigable waters was likely to disrupt maritime commercial activity and there was a substantial relationship between a traditional maritime activity in the kind of activity that arose from the fire which was the “storage and maintenance of a vessel on navigable water.” Thus, the trilogy of cases outlined a two-pronged test for determining whether an admiralty court could exercise tort jurisdiction over a claim: o Does the event satisfy the locality test? o Was the event a maritime activity and was the event disruptive to maritime commerce? In this case the alleged tort was committed on navigable water. Great Lakes also proved the connection with maritime activity by showing how the damage caused by a vessel on navigable water to an underwater structure is potentially disruptive to maritime commerce....