Blackton v. Gordon
Headline: Court rules ship captains are not protected by federal exemption for seamen’s wages, allowing creditors to garnish a captain’s pay under state attachment law.
Holding: The Court held that the federal law exempting seamen’s wages from attachment does not include a ship’s master, allowing a creditor to garnish a captain’s pay under the state attachment proceeding.
- Allows creditors to garnish a ship captain’s wages under state attachment law.
- Limits federal wage exemption to crew members other than masters.
- Affirms judgment against a railroad officer who refused the garnishment order.
Summary
Background
A creditor won a money judgment against the captain of the tug Waverly, who worked in New York Harbor. The creditor used a state law procedure to attach the captain’s wages owed by the Erie Railroad Company. The railroad’s marine superintendent refused to honor the attachment, claiming a federal law protected seamen’s wages from being garnished. The superintendent was sued under a local law that makes an officer who refuses to obey such orders pay the judgment; he lost at trial and on state appeals, and the Supreme Court agreed to decide the federal question.
Reasoning
The central question was whether the federal statute that says seamen’s wages cannot be attached was meant to include a ship’s master. The Court examined the 1915 law and its earlier form in an 1872 law and looked at the definitions Congress used. Those earlier provisions treated ordinary crew members as a distinct class separate from the person “having the command” of a ship. Reading the wage-exemption provision together with the original definitions, the Court concluded Congress did not intend the exemption to cover masters. The Court therefore held the captain was not entitled to the federal wage exemption.
Real world impact
As a practical matter, the decision allows creditors using valid state attachment procedures to garnish a captain’s wages owed by an employer. The ruling resolves only this statutory interpretation question; the Court did not decide other related statutory issues because its reading made them unnecessary. The judgment for the creditor was affirmed.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?