Southern Pacific Co. v. Jensen

Supreme Court of the United States · 1917 · Federal Courts

Federal CourtsAdmiraltyMaritime LawState-Federal Relationsadmiralty jurisdictionmaritime lawuniformitystate workers' compensation

Facts

Christen Jensen worked for Southern Pacific Company loading and unloading cargo from the steamship El Oriente while it was berthed at a New York pier in navigable waters of the United States. He drove an electric freight truck between the ship and the pier over a gangway and was killed when, while backing the loaded truck into the ship's hatchway, he struck his head and broke his neck. New York's Workmen's Compensation Commission found the injury arose out of and in the course of employment and awarded weekly compensation and funeral expenses to his widow and children. Southern Pacific objected, arguing among other things that the federal Employers' Liability Act did not apply and that application of the New York statute conflicted with maritime law and federal admiralty jurisdiction.

Issue

May New York constitutionally apply its Workmen's Compensation Act to the death of a stevedore injured while performing maritime work on navigable waters? Also, did the Federal Employers' Liability Act govern instead because the employer was a railroad common carrier?

Rule

The Federal Employers' Liability Act applies only where the parties are engaged in matters having a direct and substantial connection with railroad operations, not distinct ocean-going carriage merely because the vessel is owned by a railroad company. In maritime matters, state legislation is invalid if it contravenes an applicable act of Congress, or works material prejudice to the characteristic features of the general maritime law, or interferes with the proper harmony and uniformity of that law in its interstate and international relations; remedies not known to the common law and not enforceable by ordinary court processes are not preserved by the saving-to-suitors clause.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Lena Ortiz works for Harbor Span Logistics, a fictional cargo-handling company in Baltimore, unloading steel coils from an ocean-going freighter tied up in navigable waters. Maryland applies a compulsory no-fault compensation statute that requires vessel operators using its docks to secure insurance or pay into a state fund and provides scheduled benefits regardless of negligence.

If Lena is injured aboard the freighter while moving cargo, which is the best argument against applying the Maryland statute to her claim?

Explanation. The majority treated stevedoring and related cargo work on navigable waters as maritime in nature. A compulsory state compensation scheme that imposes new liabilities on ships using local ports and substitutes a no-fault scheduled remedy would materially prejudice characteristic features of the general maritime law and interfere with its required harmony and uniformity. The Court did not say states may never affect maritime matters, only that they may not do so beyond those limits.