## Facts

- Chelentis served as a fireman aboard the steamship *J. L. Luckenbach*.
- While at sea in December 1915, he was ordered to work on deck during heavy wind conditions.
- A wave came aboard, knocked him down, and broke his leg.
- He received immediate care; upon arrival he was hospitalized for three months, and his leg was amputated.
- He alleged his injury resulted from negligence and an improvident order by a superior officer.
- He filed a common-law action seeking full indemnity and did not claim unseaworthiness.
- He expressly disclaimed any claim for maintenance, cure, or wages.

## Issues

1. Whether a seaman injured at sea by crew negligence may recover full common-law damages in an action at law, or is limited to maintenance, cure, and wages under general maritime law.
2. Whether § 20 of the Seamen’s Act of 1915, eliminating the fellow-servant status of commanding seamen, changes the maritime measure of an owner’s liability to a common-law negligence measure.
3. Whether the “saving to suitors” clause permits liability to be measured by state common-law standards rather than general maritime law.

## Decision

- The Supreme Court affirmed judgment for the shipowner.
- Under general maritime law, when a seaman is injured in service of the ship by crew negligence (including a superior officer), the owner’s liability is limited to maintenance, cure, and wages.
- State law cannot expand that liability to full common-law indemnity.
- Section 20 of the Seamen’s Act did not substitute a common-law damages regime for the maritime rule.
- The saving to suitors clause preserves a common-law forum and remedy to enforce maritime rights, but does not allow substitution of common-law standards for maritime standards of liability.

## Legal Principles

- A seaman’s employment relationship is maritime; substantive rights and liabilities are determined by general maritime law, regardless of whether suit is brought in admiralty or at law.
- For injuries caused by crew negligence, absent unseaworthiness or a valid federal statutory change, the seaman’s recovery against the owner is limited to maintenance, cure, and wages.
- The saving to suitors clause preserves remedies and fora competent to enforce maritime rights, but does not alter the substantive maritime rule or allow state law to enlarge maritime liability.
- State rules that materially alter characteristic features of general maritime law or disrupt its uniformity cannot govern maritime liabilities.

## Conclusion

The Court held that a seaman could not obtain full common-law damages for an at-sea injury caused by crew negligence by suing at law and invoking state standards; general maritime law supplied the exclusive substantive measure of the owner’s liability, limited to maintenance, cure, and wages, and neither the Seamen’s Act § 20 nor the saving to suitors clause changed that result.


Chelentis v. Luckenbach S.S. Co., 247 U.S. 372 (1918)