State Law as an Aid to Interpretation of Admiralty Law

The U.S. constitution grants original jurisdiction in admiralty cases to federal courts[i].  Most of the cases in admiralty law are in rem which fall under federal courts jurisdiction.  However, in most admiralty cases, state or federal courts have concurrent jurisdiction depending on the “saving to suitors” clause to entertain in personam claims.  The saving to suitors clause states that common law remedies in state courts can be obtained only where there is a single claimant, or where the total claim does not exceed the value of the limitation fund.

Generally, state courts apply substantive federal maritime law to maritime cases and follow the U.S. Supreme court’s decisions in maritime cases.  However, in order to protect rights that are embedded in state law, states apply substantive state laws to determine issues.  On the other hand, when no federal statutes or decisions help in determining answer to maritime issues, federal courts can apply substantive state laws[ii]. However, application of state laws should not be prejudicial to the nation’s interest or to features of general maritime law[iii]. In circumstances where federal statutes and decisions are silent regarding a maritime issue in a case, federal courts can borrow the support of similar state laws to interpret federal maritime principles[iv].

Growth in admiralty law is the result of adoption of new rules and principles by federal courts.  Most of these new principles have been adopted from pre existing state laws[v]. Common law principles are also applied by federal admiralty courts to determine questions of law in maritime cases.  However, common law principles can be applied to admiralty cases only to the extent that they do not conflict with existing admiralty laws[vi].

A federal admiralty court can decide whether a defendant’s act was sufficient to cause a resultant injury.  In order to reach that decision, federal courts can rely on state laws that guide regarding proximate causation requirements.  Proximate causation requirement means an event which is immediately responsible to for a consequent injury.

[i] Moses Taylor, 71 U.S. 411 (U.S. 1867)

[ii] Neal v. McGinnis, Inc., 716 F. Supp. 996 (E.D. Ky. 1989)

[iii] Doucette v. Vincent, 194 F.2d 834 (1st Cir. Mass. 1952)

[iv] Holly Marine Towing v. Baker Heavy & Highway (in Re Holly Marine Towing), 2002 U.S. Dist. LEXIS 20887 (N.D. Ill. 2002)

[v] Just v. Chambers, 312 U.S. 383 (U.S. 1941)

[vi] Budisukma Permai SDN BHD v. N.M.K. Prods., 606 F. Supp. 2d 391 (S.D.N.Y. 2009)

Inside State Law as an Aid to Interpretation of Admiralty Law