Coon v. Kennedy

Background

Rebecca Coon, a widow, sued to recover under New Jersey’s Workmen’s Compensation Act after her husband drowned on August 4, 1915. He was employed as a fireman on a tug boat and died in the State’s navigable waters. The New Jersey Court of Errors and Appeals denied her claim on March 11, 1918. That court held the federal law passed October 6, 1917, which preserves state workers’ compensation rights in some cases, did not apply to this 1915 accident, and it applied the doctrine from Southern Pacific Co. v. Jensen that maritime law governs such incidents.

Reasoning

The central question was whether the Supreme Court could review the state ruling. The New Jersey court treated the case as governed by federal maritime law rather than by the state compensation law because the death occurred before the 1917 federal saving law. The Supreme Court noted there was no decision invalidating a federal statute or treaty, nor any decision asserting a state law was valid despite conflict with federal law. Under the Act of September 6, 1916, the Court concluded the writ of error was improperly brought and must be dismissed.

Real world impact

This ruling means the widow’s appeal to the Supreme Court was ended on procedural grounds rather than resolved on whether she should receive compensation. It signals that deaths on navigable waters are to be analyzed under maritime law for claims like this, and that the 1917 federal saving provision did not help victims of accidents that occurred before it was passed. Because the Court dismissed the writ, the decision is a procedural bar to Supreme Court review, not a final national ruling on workers’ compensation claims in all such cases.