Uravic v. F. Jarka Co.

Background

An American stevedore named Anton Uravic was employed by a Delaware company and was helping to unload a ship flying the German flag in New York harbor when he was fatally injured on July 13, 1926. His family sued in New York state court, but the judge dismissed the case at the end of the family’s trial evidence. The New York Court of Appeals affirmed that dismissal, and the Supreme Court agreed to decide whether a federal law known as §33 of the Jones Act applies to stevedores working on foreign-flag ships.

Reasoning

The key question was whether the Jones Act’s phrase “any seaman” covers stevedores and whether that protection applies when they work on a foreign vessel in U.S. waters. The Court explained that the statute’s language is broad, that stevedores have been treated as covered, and that Congress can regulate conduct within U.S. territorial jurisdiction. The opinion rejected the idea that foreign law should control and said U.S. law governs safety and liability for people working in U.S. harbors. Because the statute removes the old rule that a fellow servant’s negligence is a defense, the Court held the law protects American stevedores even when they are on a foreign-flag ship.

Real world impact

The ruling means American dockworkers injured or killed while unloading foreign ships in U.S. harbors can seek damages under the federal statute. Employers and vessel owners may face liability even for injuries caused by another worker. The Court left open the possibility that specific contracts or unusual facts could create exceptions, but on the facts before it the judgment for the defendants was reversed.