## Facts

- American President Lines, Ltd., an ocean carrier, contracted with Green Transfer and Storage, Inc. to “load, stuff, and secure” reels of aluminum cables into shipping containers “in a fashion suitable for ocean carriage.”
- Green loaded the containers in Portland, Oregon; the containers were then transported to Seattle, Washington, placed aboard an American vessel, and shipped to Japan.
- During the voyage, the cable reels shifted, damaging the cargo containers.
- American sued Green for breach of contract and negligence, alleging Green failed to perform in a workmanlike manner and that improper loading caused the shifting and resulting damage.
- American invoked admiralty jurisdiction under 28 U.S.C. § 1333 and Fed. R. Civ. P. 9(h); Green contested subject-matter jurisdiction and demanded a jury trial.

## Issues

1. Whether a contract for land-based loading and securing of cargo into containers in preparation for ocean shipment is a maritime contract supporting admiralty jurisdiction.
2. If not, whether negligent loading on land that causes damage during an ocean voyage constitutes a maritime tort within admiralty jurisdiction.

## Decision

- The court held the parties’ agreement was a maritime contract because its subject matter was the safe preparation of cargo for ocean carriage.
- Admiralty jurisdiction existed under 28 U.S.C. § 1333; the place of performance on land did not defeat jurisdiction.
- Green’s jurisdictional challenge (and related jury-trial demand) was denied; the case proceeded in admiralty.
- Because contract-based admiralty jurisdiction was established, the court did not need to decide the tort-jurisdiction theory in depth.

## Legal Principles

- Admiralty contract jurisdiction turns on the contract’s nature and subject matter, not the location of performance or breach.
- A contract is maritime if it relates to a ship in its use as such, or to commerce or navigation on navigable waters.
- The “character of the work” controls; services functionally equivalent to traditional maritime cargo-handling (loading/securing for sea transport) are maritime in nature.
- Contracts closely connected to ocean carriage may fall within admiralty even when performed entirely shoreside, where the work directly affects cargo safety during the voyage.

## Conclusion

The court concluded that an agreement to load and secure cargo in containers specifically for ocean shipment is maritime in character, bringing the dispute within federal admiralty jurisdiction even though the loading occurred on land.


Am. President Lines, Ltd. v. Green Transfer & Storage, Inc., 568 F. Supp. 58 (D. Or. 1983)