Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., 513 US 527 – Supreme Court 1995
A federal court’s authority to hear cases in admiralty flows initially from the Constitution, which “extend[s]” federal judicial power “to all Cases of admiralty and maritime Jurisdiction.” U. S. Const., Art. III, § 2. Congress has embodied that power in a statute giving federal district courts “original jurisdiction . . . of . . . [a]ny civil case of admiralty or maritime jurisdiction . . . .” 28 U. S. C. § 1333(1).
The traditional test for admiralty tort jurisdiction asked only whether the tort occurred on navigable waters. If it did, admiralty jurisdiction followed; if it did not, admiralty jurisdiction did not exist. See, e. g., Thomas v. Lane, 23 F. Cas. 957, 960 (No. 13902) (CC Me. 1813) (Story, J., on Circuit). This ostensibly simple locality test was complicated by the rule that the injury had to be “wholly” sustained on navigable waters for the tort to be within admiralty. The Plymouth, 3 Wall. 20, 34 (1866) (no jurisdiction over tort action brought by the owner of warehouse destroyed in a fire that started on board a ship docked nearby). Thus, admiralty courts lacked jurisdiction over, say, a claim following a ship’s collision with a pier insofar as it injured the pier, for admiralty law treated the pier as an extension of the land. Martin v. West, 222 U. S. 191, 197 (1911); Cleveland Terminal & Valley R. Co. v. Cleveland S. S. Co., 208 U. S. 316, 319 (1908).
This latter rule was changed in 1948, however, when Congress enacted the Extension of Admiralty Jurisdiction Act, 62 Stat. 496. The Act provided that
“[t]he admiralty and maritime jurisdiction of the United States shall extend to and include all cases of damage or injury, to person or property, caused by a vessel on navigable water, notwithstanding that such damage or injury be done or consummated on land.” 46 U. S. C. App. § 740.
The purpose of the Act was to end concern over the sometimes confusing line between land and water, by investing admiralty with jurisdiction over “all cases” where the injury was caused by a ship or other vessel on navigable water, even if such injury occurred on land. See, e. g., Gutierrez v. Waterman S. S. Corp., 373 U. S. 206, 209-210 (1963); Executive Jet Aviation, Inc. v. Cleveland, 409 U. S. 249, 260 (1972).
After this congressional modification to gather the odd case into admiralty, the jurisdictional rule was qualified again in three decisions of this Court aimed at keeping a different class of odd cases out. In the first case, Executive Jet, supra, tort claims arose out of the wreck of an airplane that collided with a flock of birds just after takeoff on a domestic flight and fell into the navigable waters of Lake Erie. We held that admiralty lacked jurisdiction to consider the claims. We wrote that “a purely mechanical application of the locality test” was not always “sensible” or “consonant with the purposes of maritime law,” id., at 261, as when (for example) the literal and universal application of the locality rule would require admiralty courts to adjudicate tort disputes between colliding swimmers, id., at 255. We held that “claims arising from airplane accidents are not cognizable in admiralty” despite the location of the harm, unless “the wrong bear[s] a significant relationship to traditional maritime activity.” Id., at 268.
The second decision, Foremost Ins. Co. v. Richardson, 457 U. S. 668 (1982), dealt with tort claims arising out of the collision of two pleasure boats in a navigable river estuary. We held that admiralty courts had jurisdiction, id., at 677, even though jurisdiction existed only if “the wrong” had “a significant connection with traditional maritime activity,” id., at 674. We conceded that pleasure boats themselves had little to do with the maritime commerce lying at the heart of the admiralty court’s basic work, id., at 674-675, but we nonetheless found the necessary relationship in
“[t]he 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 . . . ,” id., at 675.
In the most recent of the trilogy, Sisson v. Ruby, 497 U. S. 358 (1990), we held that a federal admiralty court had jurisdiction over tort claims arising when a fire, caused by a defective washer/dryer aboard a pleasure boat docked at a marina, burned the boat, other boats docked nearby, and the marina itself. Id., at 367. We elaborated on the enquiry exemplified in Executive Jet and Foremost by focusing on two points to determine the relationship of a claim to the objectives of admiralty jurisdiction. We noted, first, that 534*534 the incident causing the harm, the burning of docked boats at a marina on navigable waters, was of a sort “likely to disrupt [maritime] commercial activity.” 497 U. S., at 363. Second, we found a “substantial relationship” with “traditional maritime activity” in the kind of activity from which the incident arose, “the storage and maintenance of a vessel. . . on navigable waters.” Id., at 365-367.
After Sisson, then, a party seeking to invoke federal admiralty jurisdiction pursuant to 28 U. S. C. § 1333(1) over a tort claim must satisfy conditions both of location and of connection with maritime activity. A court applying the location test must determine whether the tort occurred on navigable water or whether injury suffered on land was caused by a vessel on navigable water. 46 U. S. C. App. § 740. The connection test raises two issues. A court, first, must “assess the general features of the type of incident involved,” 497 U. S., at 363, to determine whether the incident has “a potentially disruptive impact on maritime commerce,” id., at 364, n. 2. Second, a court must determine whether “the general character” of the “activity giving rise to the incident” shows a “substantial relationship to traditional maritime activity.” Id., at 365, 364, and n. 2. We now apply the tests to the facts of this suit.