## Facts

- Passengers paid passage money to Basil Hanioti for transportation to Europe on the vessel *City of Athens*, scheduled to sail July 15, 1947.
- Hanioti held the vessel out as a common carrier of passengers for hire and conducted business under his own and various trade names.
- The voyage was abandoned, and the passengers did not receive the contracted transportation.
- The passengers alleged Hanioti wrongfully appropriated the passage money to his own use, failed to refund it, and engaged in acts intended to hinder recovery, including secreting himself and manipulating assets.
- The passengers filed a libel in admiralty seeking return of the passage money, using allegations that resembled fraud and unjust enrichment.

## Issues

1. Whether a claim for return of passage money paid under a maritime passenger transportation contract, alleging abandonment of the voyage and wrongful retention of funds, falls within federal admiralty jurisdiction.
2. Whether admiralty jurisdiction is defeated when the libel’s allegations resemble common-law “money had and received” or sound in fraud, rather than stating breach of contract in technical form.

## Decision

- The Supreme Court reversed the court of appeals and remanded.
- The Court held the libel stated a cause of action within federal admiralty jurisdiction.
- The Court concluded the allegations of wrongfulness and fraud did not change the essential character of the claim, which arose from breach of a maritime passenger contract.
- The decision was unanimous, with the opinion authored by Justice Douglas.

## Legal Principles

- A contract for the transportation of passengers is a maritime contract within admiralty jurisdiction.
- Admiralty jurisdiction turns on whether the claim arises out of a maritime contract, not on whether the pleading resembles a common-law form of action.
- Admiralty jurisdiction may exist even where the claim reads like “money had and received” or unjust enrichment, if the obligation to refund is grounded in breach of a maritime contract.
- Allegations sounding in fraud or wrongful withholding do not remove a case from admiralty when they merely describe the manner of nonperformance or nonpayment connected to a maritime obligation.
- Admiralty pleading is not governed by rigid technical forms; courts look to the substance of the asserted maritime right.

## Conclusion

Because the passengers’ right to recover the paid passage money depended on the abandonment and breach of a maritime passenger transportation contract, the federal district court had admiralty jurisdiction even though the libel used fraud-like and restitutionary allegations to describe the wrongful retention of the funds.


Archawski v. Hanioti, 350 U.S. 532 (1956)