Garrett v. Moore-Mccormack Co., Inc.

Background

A seaman sued a shipping company in Pennsylvania after being injured on a ship that traveled between the United States and European ports. He spent months in hospitals in Gdynia, Poland, and in the United States. Days after returning to the U.S. he signed a $100 release; he later said his signature was obtained by fraud and while he was under the influence of pain medication and threats. A jury awarded him damages and maintenance; the state trial court later set that verdict aside because Pennsylvania law required the seaman to meet a very high proof standard to invalidate a written release.

Reasoning

The Court examined whether a state court must apply federal admiralty rules when a seaman sues under the Jones Act and for maintenance and cure. It held that federal maritime law governs the substantive rights and the proof rules that protect seamen. The Court said seamen are treated as wards of admiralty and Congress intended strong protections for them. Therefore, a party relying on a seaman’s release must prove it was signed freely, with full understanding, and without deception or coercion; the local Pennsylvania rule placing the heavy burden on the seaman conflicted with federal law.

Real world impact

The Supreme Court reversed the state court’s decision and required that state courts give plaintiffs the full benefit of federal admiralty protections in similar cases. Employers or carriers now bear the burden of proving a release’s validity in seamen injury cases, and state procedural rules cannot be used to weaken federal maritime rights. This ruling applies to Jones Act claims and maintenance-and-cure claims and aims for uniform protection of seamen across the country.