According to the U.S. Constitution, judicial power extends to all cases of admiralty and maritime jurisdiction.[i] By constitutional provision federal district courts of the have exclusive jurisdiction of all civil cases of admiralty and maritime jurisdiction.[ii] Furthermore, state and local laws can never confer jurisdiction on the courts of the United States.[iii] Also, state courts are excluded from taking jurisdiction of civil maritime cases.[iv]
In The Willapa, 25 Ore. 71 (Or. 1893), the court held that the principal subjects of admiralty jurisdiction are maritime contracts and maritime torts. The court held that contracts for repair and supplies of a vessel in her home port are maritime contracts and the federal courts could exercise admiralty jurisdiction over those matters. Similarly, a cause of action founded on such a contract is a civil cause of admiralty and maritime jurisdiction, and exclusively cognizable in the federal courts. Also, jurisdiction of courts of admiralty, in matters of contract, depends upon the nature and character of the contract; but in torts, it depends entirely on locality.[v]
Exclusive original cognizance of all civil causes of admiralty and maritime jurisdiction is on the federal district courts. The jurisdiction of district courts include all seizures under the laws of impost, navigation, or trade of the U.S., where the seizures are made on waters that are navigable from the sea by vessels of ten or more tons burden, within their respective districts as well as upon the high seas.[vi] In Belfast, 74 U.S. 624 (U.S. 1869), the court held that even though original cognizance of admiralty matters is exclusive in the federal district courts, the suitor may elect to pursue a common law remedy in the state courts or in the circuit court in all cases where such a remedy is applicable. Also, common law remedies are not applicable to enforce a maritime lien by a proceeding in rem, and consequently the original jurisdiction to enforce such a lien by that mode of proceeding is exclusive in the federal district courts.
[i] USCS Const. Art. III, § 2, Cl 1
[ii] The Willapa, 25 Ore. 71 (Or. 1893)
[iii] Roach & Long v. Chapman, 63 U.S. 129, 132 (U.S. 1860)
[iv] The Willapa, 25 Ore. 71 (Or. 1893)
[v] The S.S. Samovar, 72 F. Supp. 574 (D. Cal. 1947)
[vi] Belfast, 74 U.S. 624 (U.S. 1869)