Federal District Courts

U.S. Const. Art. III, § 2, cl. 1 provides that the judicial power shall extend to all cases of admiralty and maritime jurisdiction.  Pursuant to 28 USCS. § 1333, federal district courts have original and exclusive jurisdiction over admiralty and maritime claims.[i] The admiralty jurisdiction of the federal courts is independent of diversity of citizenship.  Situation may arise when one statute gives a claimant the right to a common law remedy, which the claimant can properly sought in a state court; and another statute gives the claimant the right to seek a limitation of liability in a federal district court.  Jurisdiction of  a federal court is exclusive over a state court, when the federal court is competent to afford relief in limitation of liability claims.  In such case entire cause is to be disposed of by the federal court and the action in the state court may not be further prosecuted.[ii] The U S district courts possess all powers of an admiralty court, whether considered as an instance, or as a prize court.[iii]

In order to protect ship owners from being harassed by litigation in other tribunals, the questions to be settled by the statutory proceedings are:

  • If the ship or its owners are liable and;
  • If liable, whether the owners are entitled to a limitation of liability, necessarily be decided by the district court having jurisdiction over the case.

Additionally, for a district court to render its decision conclusive, the district court must have entire control of the subject to the exclusion of other courts and jurisdictions.  If another court is allowed to investigate the same questions at the same time, the following issues may arise:

  • other court can come to a conclusion contrary to that of the district court;
  • the claimant can be devoid of benefits of a relevant statute; and
  • the federal court proceedings can be frustrated.[iv]

A district court’s admiralty jurisdiction is exclusive only as to those maritime causes of action begun and carried on as proceedings in rem, that is, where a vessel or thing is itself treated as the offender.  State courts lacks jurisdiction in in rem proceeding.

Under 28 USCS § 1441, if a civil action is brought in a State court of which the U.S. district courts have original jurisdiction, the defendant can remove the case to the U.S. district court for the district and division embracing the place where such action is pending.[v]

For the purpose of service of summons, admiralty jurisdiction of a U.S. district court has been said to be coextensive with the territorial boundaries of the state where the district court is situated.  According to Fed. R. Civ. P. 4(f),.all process other than a subpoena may be served anywhere within the territorial limits of the state in which the district court is held.  If a statute of the U S provides service beyond territorial limits, it can be made beyond the territorial limits of that state.

Decisions of the federal courts have played an important part in the development of U.S. admiralty law.  However, court-made admiralty law generally applies only in the absence of relevant federal statutory law.

[i] Canino v. Londres, 862 F. Supp. 685 (D.N.H. 1994)

[ii] Langnes v. Green, 282 U.S. 531, 539-540 (U.S. 1931)

[iii] Jennings v. Carson, 1792 U.S. Dist. LEXIS 3 (D. Pa. 1792)

[iv] Maryland Casualty Co. v. Cushing, 347 U.S. 409 (U.S. 1954)

[v] Canino v. Londres, 862 F. Supp. 685 (D.N.H. 1994)


Inside Federal District Courts