Jackson v. S. S. "Archimedes"

Background

A group of British seamen signed on at Manchester in May 1922 to sail on the Archimedes, a British ship, for a round trip to New York and back. They received customary wage advances in England and later got additional payments from the ship’s master while in New York. After demanding one-half of their earned wages and being refused, they left the ship and sued in a U.S. court, arguing that a federal law invalidated the English advances and entitled them to full pay in the United States.

Reasoning

The Court examined whether Section 10 of the Dingley Act, as amended by the Seamen’s Act of 1915 and the Merchant Marine Act of 1920, reached advances paid by foreign ships in foreign ports. It reviewed earlier decisions holding that the 1915 law applied only to acts in U.S. waters and did not void foreign advances made where local law allowed them. The 1920 amendment added the phrase “whether made within or without the United States,” but did not alter the separate provision that expressly limits the law’s reach to foreign vessels while in U.S. waters nor the criminal penalties that imply territorial limits. Reading the amendment in context, the Court found no clear congressional intent to reach advances paid by foreign vessels in foreign ports.

Real world impact

The Court affirmed the lower courts and rejected the seamen’s claim. The practical result is that customary advances paid under foreign law remain valid and may be deducted when seamen seek wages in U.S. courts, and the statutory prohibition on advance wages remains focused on acts in U.S. waters.