Facts
- Clyde Richardson and Shirley Eliser each operated small pleasure boats on the Amite River, a navigable waterway in Louisiana.
- The boats collided, killing Richardson.
- Richardson’s widow and heirs sued Eliser and Eliser’s insurer, Foremost Insurance Company, in federal court, alleging negligence.
- Plaintiffs invoked federal admiralty jurisdiction under 28 U.S.C. § 1333(1).
- Neither vessel had been used for commercial purposes; both were purely recreational.
Issues
- Whether a tort claim arising from a collision between two pleasure boats on navigable waters falls within federal admiralty jurisdiction under 28 U.S.C. § 1333(1).
- Whether admiralty jurisdiction requires that the incident bear a significant relationship to traditional maritime activity and, if so, whether that relationship must be commercial in nature.
Decision
- The Supreme Court affirmed the Fifth Circuit and held that the case fell within federal admiralty jurisdiction.
- A complaint alleging a collision between two vessels, including pleasure boats, on navigable waters states a claim within admiralty jurisdiction.
- The Court applied the “significant relationship to traditional maritime activity” requirement beyond aviation cases.
- The Court rejected any rule limiting admiralty jurisdiction to incidents involving commercial maritime activity.
Legal Principles
- Admiralty tort jurisdiction generally requires both: (1) locality on navigable waters and (2) a significant relationship to traditional maritime activity.
- The “significant relationship to traditional maritime activity” requirement applies outside the aviation context.
- Navigation and collision of vessels on navigable waters are traditional maritime activities sufficient to satisfy the maritime nexus requirement.
- Admiralty jurisdiction does not depend on whether a vessel is engaged in commercial use; uniform federal navigation rules apply to all vessel operators on navigable waters.
Conclusion
Federal admiralty jurisdiction extends to wrongful-death and negligence claims arising from collisions between recreational vessels on navigable waters because vessel navigation is a traditional maritime activity and the jurisdictional inquiry does not turn on commercial use.