American Dredging Company v. Miller

PETITIONER: American Dredging Company
LOCATION: Residence of Margaret Gilleo

DOCKET NO.: 91-1950
DECIDED BY: Rehnquist Court (1993-1994)
LOWER COURT: Louisiana Supreme Court

CITATION: 510 US 443 (1994)
ARGUED: Nov 09, 1993
DECIDED: Feb 23, 1994

George W. Healy III - for the Maritime Law Association of the United States as amicus curiae urging reversal
John F. Manning - on behalf of the United States, as amicus curiae, supporting the Respondent
Lizabeth L. Burrell - for the Maritime Law Association of the United States as amicus curiae urging reversal
Timothy J. Falcon - on behalf of the Respondent
Thomas J. Wagner - on behalf of the Petitioner

Facts of the case

Robert Miller, a Mississippi resident who had moved north to find work, was injured while working as a seaman for American Dredging Company, a Pennsylvania corporation with its principal place of business in New Jersey. Miller returned home to Mississippi, and filed a suit against the company in the Civil District Court for the Parish of Orleans, Louisiana. The suit was filed under the Jones Act, a federal law that allows a seaman to sue his employer in either federal or state court when he suffers personal injury.

American Dredging moved to dismiss the case under the doctrine of "forum non conveniens," which allows a court to dismiss a case if it is filed in a place that is unnecessarily and significantly inconvenient to the defendant. The trial court agreed, holding that a Louisiana law making the doctrine of "forum non conveniens" inapplicable in Jones Act cases was superseded by federal maritime law (law that deals with oceanic commerce). An appeals court affirmed the decision, but the Louisiana Supreme Court overturned it, holding that the Louisiana law was not superseded by federal maritime law.


Does the Constitutional grant of federal jurisdiction over maritime law (found in Article III Section 2) prevent states from prohibiting (in maritime cases) "forum non conveniens" claims that, under federal law, would be permitted?

Media for American Dredging Company v. Miller

Audio Transcription for Oral Argument - November 09, 1993 in American Dredging Company v. Miller

Audio Transcription for Opinion Announcement - February 23, 1994 in American Dredging Company v. Miller

William H. Rehnquist:

The opinion of the Court in No. 91-1950, American Dredging Company against Miller will be announced by Justice Scalia.

Antonin Scalia:

This case is here on certiorari from the Supreme Court of Louisiana.

The respondent, William Robert Miller, was injured while working as a seaman board a tug operating on the Delaware River and owned by the petitioner, American Dredging Company, a Pennsylvania Corporation with its principal place of business in New Jersey.

After returning home to Mississippi, Miller brought this action for damages under what is called the savings to suitors clause of the United States Code, 28 U.S.C. Section 1333(1), and under the Jones Act which is 46 U.S.C. App. Section 688.

He brought that suit in the Civil District Court, the State District Court, for Orleans, Louisiana.

That court, however, granted American Dredging's motion to dismiss based on the doctrine of forum non conveniens under which a court may decline to exercise jurisdiction if a more appropriate forum exists.

The District Court concluded that federal maritime law which governs the merits of Miller's claim required application of forum non conveniens not withstanding the fact that the Louisiana Code of Civil Procedure purports to render that doctrine unavailable in maritime cases brought in Louisiana State Courts.

The Supreme Court of Louisiana reversed holding that Louisiana's statutory prohibition of forum non conveniens is not preempted by federal maritime law.

We granted certiorari and now affirm.

In admiralty cases filed in a State Court, federal law does not preempt state law regarding the doctrine of forum non conveniens.

We have long held that State Court's hearing admiralty cases may adapt such remedies as they see fit so long as those remedies do not materially prejudice what we have called characteristic features or interfere with the proper uniformity of admiralty law.

Because forum non conveniens did not originate in admiralty and is a doctrine of general application not limited to admiralty, we think it not a characteristic feature of admiralty law.

Moreover, application of forum non conveniens is not necessary to assure proper uniformity of admiralty law for two reasons: First, it is really a supervening venue rule procedural in nature rather than a substantive rule upon which maritime actors rely in making decisions about how to manage their business affairs; and secondly, it is unlikely to produce uniformed results anyway because the doctrine vests enormous discretion in the Trial Court and encompasses multifarious factors in its application.

Our conclusion is confirmed by prior decisions under the Jones Act and the Federal Employers Liability Act which imply that federal venue rules including forum non conveniens are matters of judicial housekeeping prescribed only for the Federal Courts.

Justice Souter has filed a concurring opinion; Justice Stevens has filed an opinion concurring in part and concurring in the judgment; Justice Kennedy has filed a dissenting opinion which is joined by Justice Thomas.