Pursuant to Article III, Section 2, clause 1 of the U.S. Constitution, the judicial power of the United States shall extend to all cases “of admiralty and maritime jurisdiction.” Therefore, this provision lays down the specific foundation for admiralty jurisdiction in the federal courts. Congress employs the terms “admiralty” and “maritime” interchangeably.
Congress and the state legislatures have the power to fix the substantive law which the federal admiralty courts are to apply. However, it is not within the power of these law-making bodies to determine the sphere of admiralty jurisdiction. This has been held, as a purely judicial function.
For instance, in Steamer St. Lawrence, 66 U.S. 522 (U.S. 1862), the boat owner hired the repairmen to make repairs to his boat. The owner later sold the boat to the buyers. The repairmen then filed an action against the buyers asserting their lien against the vessel to satisfy their claim for payment. The trial court found in favor of the repairmen. On review, the buyers argued that it was the previous owner who incurred the debt, and that they had no notice of the repairmen’s claim. Furthermore, they argued that the lien could not be enforced because it was created by state law and not recognized by maritime law. However, the United States Supreme Court found that state law created the lien and that it had the authority to enforce it. Furthermore, even though the buyers purchased the boat without notice of the incumbrance, the Court found that, that was no defense to the repairmen’s lien. Therefore, the trial court’s decision was affirmed.
In St. Lawrence, Chief Justice Taney declares, “Certainly no state law can enlarge the admiralty jurisdiction nor can an act of Congress or rule of court make it broader than the judicial power may determine to be its true limits. And this boundary is to be ascertained by a reasonable and just construction of the words used in the Constitution, taken in connection with the whole instrument, and the purposes for which admiralty and maritime jurisdiction was granted to the Federal Government.” In Lottawanna, 88 U.S. 558 (U.S. 1875), Justice Bradley says: “The question as to the true limits of maritime law and maritime jurisdiction, is, undoubtedly, as Chief Justice Taney intimates, exclusively a judicial question and no state law or act of Congress can make it broader, or (it may be added) narrower, than the judicial power may determine those limits to be.
The Constitution fixed only the original jurisdiction of the Supreme Court as to admiralty cases, and Congress may mold the scope of the federal courts’ admiralty jurisdiction. Moreover, the constitutional provision is not self-defining, but presupposes a knowledge of what “admiralty and maritime jurisdiction” means and thus leaves it to judicial interpretation to establish in a more concrete way the scope or limits of admiralty jurisdiction.
The constitutional provision impliedly contains the following grants:
- it empowers Congress to confer admiralty and maritime jurisdiction on the tribunals inferior to the Supreme Court;
- it empowers the federal courts in their exercise of admiralty and maritime jurisdiction to draw on the substantive law inherent in that jurisdiction; and
- it empowers Congress to revise and supplement the maritime law within the limits of the U.S. Constitution.