Garrett v. Moore-McCormack Co.

Background

A seaman was injured while working on a ship traveling between U.S. and European ports and sued in a Pennsylvania state court for damages under the Jones Act and for maintenance and cure (medical and living expenses). He claimed a hatch cover fell on him; the employer disputed the cause and said the seaman had signed a $100 release. The seaman said the signature was obtained by fraud, while the employer said the payment settled all claims. A jury found for the seaman, but a Pennsylvania en banc court set the verdict aside because the seaman had not met Pennsylvania’s unusually high proof standard for attacking a release. The Pennsylvania Supreme Court affirmed on a procedural-ground theory.

Reasoning

The central question was whether state courts enforcing federal maritime rights must use federal admiralty rules (admiralty means the federal legal tradition for shipping and seamen). The Court held that when a state hears a federal maritime claim it must apply the substantive protections of admiralty law. Under admiralty rules, a seaman is protected as a vulnerable party and the employer who asserts a release must prove it was freely made, without deception or coercion, and fully understood. The adequacy of the payment, and the medical or legal advice available when the release was signed, are relevant to that inquiry. The Court reversed the Pennsylvania decision.

Real world impact

The ruling requires state courts hearing seamen’s federal claims to follow uniform federal maritime rules. Injured seamen get protection against heavy state proof requirements when challenging releases, and employers must show releases were valid. The case preserves national uniformity for Jones Act and maintenance-and-cure claims.