Lewis v. Lewis & Clark Marine, Inc.

PETITIONER: Lewis
RESPONDENT: Lewis & Clark Marine, Inc.
LOCATION: Kyllo's Home

DOCKET NO.: 99-1331
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 531 US 438 (2001)
ARGUED: Nov 29, 2000
DECIDED: Feb 21, 2001

ADVOCATES:
James V. O'Brien - Argued the cause for the respondent
Roy C. Dripps, III - Argued the cause for the petitioner

Facts of the case

In 1998, James F. Lewis, a deckhand aboard the M/V Karen Michelle owned by Lewis & Clark Marine, Inc., claimed that he was injured when he tripped over a wire on the boat. Lewis then sued Lewis & Clark in Illinois County Court, for personal injuries claiming negligence under the Jones Act. Lewis & Clark had already filed a complaint for exoneration from, or limitation of, liability in the District Court under the Limitation of Liability Act (Act). Subsequently, the court approved a surety bond of $450,000, representing Lewis & Clark's interest in the vessel, ordered that any claim related to the incident be filed with the court within a specified period, and enjoined the filing or prosecution of any suits related to the incident. The injunction prevented Lewis from litigating his personal injury claims in state court and he moved to dissolve it. The District Court noted that federal courts have the exclusive jurisdiction to determine whether a vessel owner is entitled to limited liability, but also recognized that the statute conferring exclusive jurisdiction over admiralty and maritime suits to federal courts saves to suitors "all other remedies to which they are other wise entitled." Ultimately, the court dissolved the injunction. The Court of Appeals reversed.

Question

Did a District Court abuse its discretion when it dissolved an injunction under the Limitation of Liability Act, which prevented a seaman from suing a vessel owner in state court for personal injuries sustained aboard the vessel?

Media for Lewis v. Lewis & Clark Marine, Inc.

Audio Transcription for Oral Argument - November 29, 2000 in Lewis v. Lewis & Clark Marine, Inc.

Audio Transcription for Opinion Announcement - February 21, 2001 in Lewis v. Lewis & Clark Marine, Inc.

William H. Rehnquist:

The opinion of the Court in No. 99-1331, Lewis versus Lewis & Clark Marine Inc. will be announced by Justice O’Connor.

Sandra Day O'Connor:

This case is here on writ of certiorari to the United States Court of Appeals for the Eighth Circuit.

The petitioner James Lewis claims he was injured while on board the respondent Lewis & Clark ship while working as a deckhand.

The petitioner sued the respondent for his injuries in the Illinois State Court.

The petitioner did not ask for a jury trial.

In anticipation of petitioner’s lawsuit, the respondent ship owner filed a complaint in Federal District Court under the Limitation of Liability Act.

The Limitation Act grants vessel owners the right to seek limited liability in Federal Court for claims of damage aboard their vessels.

Another federal statute grants exclusive jurisdiction to Federal Courts over admiralty and maritime claims, but that statute also has a clause that saves the suitors like petitioners, their choice of remedies including remedies in the State Court.

The Federal District Court noted the potential tension between the Limitation Act and the saving to suitors clause.

The District Court eventually allowed the petitioner to proceed with his claims in State Court after the petitioner provided certain stipulations and waivers assuring the District Court that respondent’s right to seek limitation of liability in Federal Court would be protected.

The Court of Appeals for the Eighth Circuit reversed the District Court, concluding that litigation should have continued in the Federal Court.

The Court of Appeals held that respondent had a right to ask for exoneration from liability not just limitation of liability in Federal Court.

The Court of Appeals also held that because petitioner did not ask for a jury trial in State Court, he had not sought a saved remedy under the saving to suitors clause.

In an opinion filed with Clerk of the Court today, we reverse the judgment of the Eighth Circuit.

As the courts although recognized there is tension between the Limitation Act and the saving to suitors clause.

The Limitation Act allows vessel owners like respondent to seek limited liability in Federal Court.

The saving to suitors clause gives suitors like petitioner their choice of remedy including remedies in State Court.

The tension arises when the vessel owner wants to proceed in Federal Court and the injured suitor wants to proceed in State Court.

We believe that District Court properly resolved that tension in this case by allowing the petitioner to proceed with his claims in State Court after having protected respondent’s right to seek limited liability.

The Court of Appeals contrary conclusion had two defects we think: first, the Limitation Act does not give vessel owners the right to seek exoneration from liability where limitation of liability is not at issue; second, suitors like the petitioner have the right to their choice of remedies in State Court not just the choice of a jury trial.

The decision of the Court is unanimous.