The Troy

Background

The Duluth and Superior Bridge Company owned a swing bridge across the St. Louis River between Duluth, Minnesota, and Superior, Wisconsin. The bridge had a swinging span on a turntable, permanent abutments for streetcars and pedestrians, and openings that allowed large lake steamers to pass. On August 11, 1906, the merchant steamer Troy struck the bridge’s center pier protection and glanced into the draw, causing heavy damage. The bridge company sued in federal admiralty court in the Western District of Wisconsin for damages. The steamer’s owner objected, arguing the bridge was a land structure and the damage occurred on land, so the claim did not belong in admiralty.

Reasoning

The central question was whether this kind of bridge damage claim falls within federal admiralty (maritime) authority. The District Court sustained the steamer owner’s exceptions and dismissed the libel, and the jurisdictional question was then appealed and certified to the Supreme Court. The Court applied the same reasoning it had just used in a very similar case and concluded that the libel did not present a case within admiralty jurisdiction under the Constitution and admiralty practice. Because of that legal conclusion, the Supreme Court affirmed the dismissal; the steamer owner prevailed on the jurisdictional issue.

Real world impact

The ruling means some claims for damage to river bridges and their protective piers will not be heard in federal maritime courts. Bridge owners may need to seek recovery in other courts when admiralty jurisdiction is lacking. This decision follows and reinforces the Court’s approach in a recent similar bridge-collision case.