American Dredging Co. v. Miller

Background

A seaman from Mississippi was hired by a Pennsylvania dredging company to work on a tug called the MV John R. He was injured while working and sued in a Louisiana state court under the Jones Act and maritime law. The trial court dismissed the case on forum non conveniens grounds, but the Louisiana Supreme Court reversed, relying on a Louisiana rule that bars the forum non conveniens defense in maritime and Jones Act cases. The United States Supreme Court agreed to decide whether federal maritime law prevents states from adopting such a rule.

Reasoning

The Court held that the forum non conveniens doctrine is procedural, not a substantive part of maritime law that must be uniform nationwide. It noted the doctrine’s flexible, discretionary factors and its roots outside admiralty. The majority concluded that Congress had not required a single national rule and that the Jones Act and related laws do not preempt state rules barring forum non conveniens. The Court affirmed the Louisiana decision. One Justice (Souter) agreed but warned close cases turn on whether a state rule unduly interferes with maritime commerce. Justice Stevens concurred in part and urged abandoning older cases that broadly preempted state law.

Real world impact

The ruling allows state courts like Louisiana’s to refuse the forum non conveniens defense in maritime suits. Shipowners and other maritime defendants may face suits in state courts that cannot be dismissed for inconvenience. Federal courts can still dismiss appropriate cases under forum non conveniens, but outcomes may vary between federal and state forums.

Dissents or concurrances

Justice Kennedy dissented, warning the decision undermines uniformity and may harm maritime commerce by encouraging forum shopping and burdens on ship operators.