Strathearn Steamship Co. v. Dillon

Background

Dillon, a British seaman, signed on a British ship at Liverpool on May 8, 1916, for a voyage that included United States ports. His shipping papers said wages would be paid at the end of the voyage and barred cash advances abroad. When the ship reached Pensacola, Florida, on July 31, 1916, Dillon, who had not been paid for about two months, demanded one-half of the wages then earned. The master refused, and Dillon sued in a U.S. District Court for $125. The District Court held the demand premature; the Court of Appeals reversed, and the case came to the Supreme Court on review.

Reasoning

The Court addressed whether §4 of the Seamen’s Act lets a seaman on a foreign vessel in a U.S. harbor demand one-half of earned wages and whether the demand was premature. The Court relied on the text of the statute, which says seamen may claim half their earned wages at ports where the ship loads or delivers cargo, that contracts to the contrary are void, and that the law applies to foreign vessels with access to U.S. courts. The Court concluded Congress intended to give equal wage rights to foreign seamen in U.S. harbors and that Congress has authority to set conditions on foreign vessels using U.S. ports. The five-day phrase limits how often demands may be made, not how long a ship must stay in port, so the demand was not premature.

Real world impact

The ruling lets foreign seamen sue in U.S. courts to recover half their earned wages even when their employment contracts say otherwise. Shipmasters cannot refuse such demands simply because the vessel has not stayed five days in port. The decision enforces the statutory right as written and affirms the Court of Appeals’ judgment.