Petty v. Tennessee-Missouri Bridge Commission
Headline: Bridge commission created by two States can be sued under federal maritime law, allowing ferry workers to bring negligence claims in federal court after the compact’s 'sue and be sued' clause was accepted.
Holding: The Court held that the bi-state bridge commission waived state immunity by accepting a compact with a "sue and be sued" clause approved by Congress, making it subject to a Jones Act negligence suit in federal court.
- Allows ferry and maritime workers to sue bi-state agencies in federal court for negligence.
- Subjects interstate compacts with sue-and-be-sued clauses to federal-law interpretation.
- Makes it easier to hold state-created corporations liable under the Jones Act.
Summary
Background
A widow sued the Tennessee-Missouri Bridge Commission after her husband, a ferry employee, drowned when the ferry sank following a collision. The Commission is a joint agency created by Missouri and Tennessee under a compact approved by Congress. The widow brought a negligence claim under the Jones Act, but the lower courts dismissed the case, treating the Commission as an arm of the States and therefore immune from suit.
Reasoning
The Court asked whether the States waived their immunity by creating the bi‑state commission with a provision that it could "sue and be sued," and by having Congress approve the compact with a proviso preserving federal jurisdiction over navigable waters and interstate commerce. Relying on federal law and past decisions about government corporations, the majority concluded the compact’s language and Congress’s consent showed waiver of immunity. The Court held the Commission counts as an "employer" under the Jones Act and reversed the dismissal, allowing the negligence suit to proceed in federal court.
Real world impact
The ruling lets maritime workers and similar claimants sue some state-created or bi‑state agencies in federal court when those agencies operate in interstate commerce and the compact includes a sue-and-be-sued clause approved by Congress. The decision focuses on the compact’s terms and does not resolve every constitutional question about state immunity for all multi‑state agencies, so some related disputes could be decided differently in future cases.
Dissents or concurrances
A dissent urged deference to Missouri and Tennessee law, argued Congress did not clearly require waiver as a condition of consent, and would have left the lower-court dismissal in place.
Opinions in this case:
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