## Facts

- William Robert Miller, a Mississippi resident, worked as a seaman for American Dredging Company aboard the M/V *John R.*, a tug operating on the Delaware River.
- Miller was injured in the course of his employment and obtained medical treatment in Pennsylvania and New York, then continued treatment in Mississippi.
- Miller sued American Dredging in Louisiana state court, seeking damages under the Jones Act and additional relief under general maritime law (including unseaworthiness, wages, and maintenance and cure).
- Miller invoked the saving to suitors clause, pursuing an in personam maritime action in state court.
- American Dredging moved to dismiss on forum non conveniens grounds; Louisiana law barred forum non conveniens dismissals in Jones Act and maritime cases filed in Louisiana state courts.

## Issues

1. Whether federal maritime law preempts a state statute that makes forum non conveniens unavailable in Jones Act and general maritime actions brought in state court under the saving to suitors clause.
2. Whether denying forum non conveniens in such cases materially prejudices characteristic features of general maritime law or disrupts maritime-law uniformity under the Jensen framework.

## Decision

- The Supreme Court affirmed the Louisiana Supreme Court.
- Federal maritime law does not preempt a state rule that bars forum non conveniens in Jones Act and maritime cases brought in state court under the saving to suitors clause.
- Louisiana could apply its own procedural rule requiring its courts to retain such cases, even though a federal court might have discretion to dismiss on forum non conveniens grounds.

## Legal Principles

- Under the saving to suitors clause, state courts adjudicating in personam maritime claims may apply state procedural remedies and their incidents, so long as they do not alter substantive maritime law.
- A state rule is invalid only if it materially prejudices characteristic features of general maritime law or interferes with the proper harmony and uniformity of maritime law in interstate and international relations (Jensen standard).
- Forum non conveniens is not a characteristic feature of maritime law; it is a generally applicable, discretionary doctrine concerning venue and convenience rather than substantive maritime rights and liabilities.
- Differences among states in applying (or not applying) forum non conveniens do not, by themselves, create the type of nonuniformity that federal maritime law forbids.

## Conclusion

The Court held that a state may refuse to apply forum non conveniens in Jones Act and maritime suits filed in its courts because the doctrine is procedural and not a defining feature of maritime law; therefore, federal maritime law does not preempt Louisiana’s prohibition on forum non conveniens dismissals in those cases.


American Dredging Co. v. Miller, 510 U.S. 443 (1994)