The amount of relief that admiralty courts can offer is limited as a result of their limited jurisdiction. It is not possible for an admiralty court to enforce an independent equitable claim, even where it concerns maritime property. However, court may consider such a claim where it is necessary to do so for the complete adjustment of those rights as to which it has independent jurisdiction and to this extent will apply equitable principles and remedies. Seeking unavailable remedies does not limit the scope of admiralty jurisdiction of a court. A plaintiff alleging only an admiralty issue may have only such remedies available from the court. Usually, equitable relief may be granted to the extent for completing the adjustment of rights over which admiralty has independent jurisdiction. The application of all statutory powers derived from law, equity and admiralty by a district court judge is made possible by the unification of admiralty and other civil actions under the Federal Rules of Civil Procedure.
In Schoenamsgruber v. Hamburg American Line, 294 U.S. 454 (U.S. 1935), libels in admiralty was filed by petitioners to recover for an injury sustained by a minor while she was a passenger on a ship sailing from Hamburg, Germany to Oakland, California. Motion for arbitration was granted by the district court, while the appellate court dismissed the case holding that the orders for arbitration were interlocutory and not appealable. The dismissal of appeal was affirmed by the U.S. Supreme Court. According to the court, statute 28 U.S.C.S. § 227 only provided for an appeal of equitable actions, and not actions at law, thus making the orders not appealable.