Also known as:admiralty jurisdictions · maritime jurisdiction
Written by attorneys · grounded in primary & secondary sources — see below
The authority of federal district courts to adjudicate cases arising from maritime activities on navigable waters. Article III of the Constitution extends the judicial power to all such cases, and Congress has implemented the grant through statutes that preserve traditional maritime remedies while allowing designation of claims under the Federal Rules of Civil Procedure.
Sources & Authorities
How it applies
Common Examples
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Cargo Damage on Navigable Waters
Coastal Carrier filed suit in federal district court against Coastal Marine after cargo sustained damage during transport on navigable waters. The complaint invoked the constitutional extension of judicial power to admiralty cases. The court retained authority to hear the dispute despite a statute purporting to channel all such claims to an administrative tribunal.
Turbine Defect in Charter Voyage
East River Steamship charterers sued the turbine manufacturer after defects caused repeated engine failures and lost service time on ocean-going vessels. The complaint invoked admiralty jurisdiction and sought damages for repair costs and lost income. The federal court applied maritime law to the product-liability claims arising from the maritime contracts.
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Statutes
Federal Rules
Casebooks
Hornbooks
Study Supplements
Dictionaries
East River Steamship Corp. v. Transamerica Delaval, Inc.476 U.S. 858, 106 S.Ct. 2295, 90 L.Ed.2d 865 (1986)
Forum Selection in Maritime Contract
Stewart Organization sued Ricoh over a contract dispute involving equipment used in maritime operations. The parties had agreed to a New York forum. The district court considered transfer under section 1404(a) while recognizing that the underlying claims fell within admiralty jurisdiction.
Stewart Organization, Inc. v. Ricoh Corp.487 U.S. 22, 29 (1988)
Jury Trial in Shareholder Derivative Suit
Shareholders brought a derivative action against corporate officers for alleged mismanagement of a company engaged in maritime trade. The complaint included claims that would have been tried to a jury at common law. The court noted that admiralty jurisdiction does not automatically eliminate the right to jury trial on legal issues.
Ross v. Bernhard396 U.S. at 538 n.10
Wrongful Death on Navigable Waters
The widow of a longshoreman killed during cargo operations on a vessel sought recovery under general maritime law. The suit was filed in federal court invoking admiralty jurisdiction. The court recognized a cause of action for wrongful death even though no federal statute expressly created one.
Moragne v. States Marine Lines, Inc.398 U.S. 375, 90 S.Ct. 1772, 26 L.Ed.2d 339
State Sovereign Immunity in Maritime Suit
A tugboat captain sued his home state's port authority for injuries sustained when his vessel struck a state-owned dock. The complaint asserted claims under federal maritime law. The court dismissed the action because state sovereign immunity barred the damages suit in federal court.
Chisholm v. Georgia2 U.S. (2 Dall.) 419, 454 (1793)
Common questions
Frequently Asked
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Does Congress have power to strip federal courts of admiralty jurisdiction by assigning all maritime cases to an administrative tribunal?+
No. Article III extends the judicial power to all cases of admiralty and maritime jurisdiction. Congress may create specialized forums and encourage uniformity, but it cannot remove those cases entirely from Article III courts.
Supporting sources
When may a plaintiff designate a claim as an admiralty or maritime claim under the Federal Rules?+
A plaintiff may designate the claim when it falls within admiralty or maritime jurisdiction and also within some other basis of subject-matter jurisdiction. The designation affects the availability of Rules 14(c), 38(e), and 82 and the Supplemental Rules.
Supporting sources
Does admiralty jurisdiction require that the incident occur on navigable waters?+
Yes for most tort claims. Admiralty tort jurisdiction generally requires both a locality on navigable waters and a connection to traditional maritime activity, although the Admiralty Extension Act reaches certain injuries caused by vessels on land.
Supporting sources
Can state courts hear admiralty claims?+
State courts may hear many maritime claims under the saving-to-suitors clause of 28 U.S.C. § 1333, but federal courts have exclusive jurisdiction over in rem actions against vessels and certain other proceedings.
Supporting sources
14 U.S. (1 Wheat.) 304 (1816)Constitutional Law
…— cases arising under the Constitution, laws, and treaties of the United States; cases affecting ambassadors; and admiralty and maritime jurisdiction — appear to the framers to require that judicial power extend imperatively to all such cases either originally or on appeal. The second class — the other controversies enumerated — might…