Valley Steamship Co. v. Wattawa

Background

An injured deckhand sued his employer, a steamship company, in Ohio state court after a 1913 injury aboard the Edwin N. Ohl at Sandusky. He sought damages under Ohio law, alleging the company’s negligence. The company employed more than five men but had not joined Ohio’s first workers’ compensation fund. In defense it denied negligence, argued the injury was the worker’s fault, and claimed it was engaged in interstate commerce and therefore not subject to the state compensation law; the court struck the company’s assumption-of-risk allegation.

Reasoning

The company appealed and sought review in the Supreme Court, raising two federal arguments. First, it said applying the Ohio compensation law would burden interstate commerce. The Court said that point was without merit and did not establish a federal question for this Court. Second, the company argued that federal admiralty and maritime power made state law inapplicable. The Court said that this second argument had not been raised clearly in the lower courts and therefore could not be considered. Citing precedent, the Court dismissed the writ of error for lack of jurisdiction.

Real world impact

The practical effect is procedural. The state-court verdict for the injured deckhand remains in place. The Supreme Court declined to reach the broader federal commerce and maritime questions both because one argument lacked merit for jurisdiction and the other was not preserved in the record. The opinion also restates that, absent congressional action, states may regulate employer-employee relations within their borders even when employees are involved in interstate commerce.