Facts
- Hough & Kershaw owned a wharf on the Chicago River, along with large warehouses (packing houses) built on or alongside the wharf and filled with valuable goods.
- The Falcon, a steam propeller used in Great Lakes commerce, was anchored at the wharf on waters treated as admiralty waters.
- Through the negligence of the Falcon’s crew, a fire started aboard the vessel.
- The fire spread from the Falcon to the wharf, then to the warehouses and the goods stored there, destroying the structures and their contents.
- Hough & Kershaw filed a libel in federal district court seeking to proceed in admiralty against the owners of the Falcon.
- Because the Falcon was not seized, Hough & Kershaw attached a different vessel owned by the same owners, the Plymouth (a sister ship), as the res in the in rem admiralty action.
- The district court dismissed the libel for lack of admiralty jurisdiction; the circuit court affirmed; Hough & Kershaw sought review in the Supreme Court.
Issues
- Does federal admiralty jurisdiction cover a tort claim for damage to land-based property (a wharf, warehouses, and stored goods) caused by a fire that began on a vessel located on navigable waters?
Decision
- The Supreme Court affirmed the dismissal for want of admiralty jurisdiction.
- Admiralty tort jurisdiction depends on the place where the injury is completed.
- Because the damage complained of—the burning of the wharf, warehouses, and goods—occurred wholly on land, the case was not within admiralty, even though the fire began on the vessel.
Legal Principles
- In tort cases, admiralty jurisdiction is determined by the locality of the injury, not the locality of the negligent act.
- When the injury or damage is done wholly upon land, the fact that the cause originated on waters within admiralty jurisdiction does not make the claim a maritime tort.
- The presence of a vessel as the instrument that started the harm does not supply admiralty jurisdiction if the damage is land-based.
- Statutes extending admiralty jurisdiction to Great Lakes waters expand the geographic reach of admiralty waters, but they do not convert purely land damage into an admiralty tort.
- A plaintiff cannot create admiralty jurisdiction by attaching a vessel in rem when the underlying tort, as measured by where the damage occurred, is not maritime.
Conclusion
The Court held that federal admiralty courts lacked jurisdiction over Hough & Kershaw’s claim because the injury they sued for was the destruction of land-based structures and goods; the fact that the fire began aboard the Falcon on navigable waters did not make the tort maritime, so the admiralty libel against the attached vessel Plymouth was properly dismissed.