## Facts

- Garrett, a seaman employed by Moore-McCormack Co., was injured aboard a transatlantic vessel and received hospital treatment abroad and in the United States.
- He sued in Pennsylvania state court for (1) damages under § 33 of the Merchant Marine Act (Jones Act) and (2) maintenance and cure, alleging negligent injury from a hatch cover.
- The shipowner disputed the seriousness and cause of the injuries, suggesting alternative causes unrelated to the alleged shipboard incident.
- As a defense, the shipowner asserted Garrett had signed a written release of all claims for \$100.
- Garrett denied knowingly signing a release and alleged any signature was procured by fraud or misrepresentation and lacked valid consideration; he also claimed he was drug-impaired, threatened with imprisonment, and believed the \$100 was wages.
- The shipowner contended the payment was a settlement of all injury-related claims, that Garrett appeared unimpaired, and that no threats were made.
- A jury found for Garrett, awarding \$3,000 under the Jones Act and \$1,000 for maintenance and cure.
- The trial court entered judgment notwithstanding the verdict for the shipowner, applying Pennsylvania’s rule placing the burden on the seaman to invalidate the release; the Pennsylvania Supreme Court affirmed.

## Issues

1. In a seaman’s Jones Act and maintenance-and-cure action brought in state court, are the parties’ rights governed by federal statute and admiralty principles, presenting a federal question for review?
2. When a shipowner relies on a seaman’s release as a defense, does federal maritime law place the burden on the shipowner to prove the release’s validity?
3. Is the allocation of the burden of proof regarding a seaman’s release a substantive federal right that a state court may not alter through characterization as procedure?

## Decision

- The U.S. Supreme Court reversed and remanded.
- Federal statute and admiralty principles measure the parties’ rights in state-court Jones Act and maintenance-and-cure litigation.
- A shipowner invoking a seaman’s release bears the burden of proving the release was executed freely, without deception or coercion, and with the seaman’s full understanding of his rights.
- This admiralty rule applies to both maintenance-and-cure claims and Jones Act damages claims.
- The seaman’s entitlement to this burden allocation is a substantive federal right; the state court erred by applying a conflicting state burden-of-proof rule to invalidate the jury’s verdict.

## Legal Principles

- In state-court actions under the Jones Act and for maintenance and cure, federal substantive maritime law governs the incidents of the claim.
- A seaman’s release is subject to careful scrutiny; the shipowner must prove voluntariness, absence of deception or coercion, and the seaman’s full understanding of rights.
- In assessing “full understanding,” courts may consider the adequacy of consideration and the medical and legal advice available at signing.
- Section 33 of the Merchant Marine Act is liberally construed for seamen’s protection and is implemented through admiralty rules not inconsistent with the Act.
- A state may not shift to the seaman the burden to invalidate a written release when federal maritime law assigns that burden to the shipowner.

## Conclusion

The Court held that federal maritime law controls the effect of a seaman’s release in state-court Jones Act and maintenance-and-cure actions, requiring the shipowner to prove the release’s knowing and voluntary execution; a contrary state burden-of-proof rule impermissibly alters a substantive federal right.


Garrett v. Moore-McCormack Co., 317 U.S. 239 (1942)