## Facts

- Chicago hired Great Lakes Dredge & Dock Co. to perform pile-driving work in the Chicago River to protect bridge piers.
- Great Lakes operated from a crane mounted on a barge while driving piles into the riverbed.
- A freight tunnel ran beneath the river and connected to multiple downtown building basements.
- Plaintiffs alleged Great Lakes negligently weakened the tunnel during the pile-driving work, and that the City of Chicago had improperly maintained the tunnel.
- Months later, river water flooded into the tunnel and then into numerous building basements, causing extensive property damage.
- Building owners and others filed Illinois state-court negligence actions against Great Lakes and the City.
- Great Lakes filed a federal limitation action seeking admiralty jurisdiction and limitation of liability under the Limitation of Vessel Owner’s Liability Act.

## Issues

1. Whether the tort claims underlying the limitation action satisfy the admiralty tort jurisdiction requirements of (a) location and (b) connection to maritime activity.
2. Whether admiralty jurisdiction may be denied based on an additional requirement that the damage be close in time and space to the vessel’s conduct, beyond proximate causation.
3. Whether the presence of non-maritime actors (e.g., a city alleged to have land-based maintenance duties) defeats admiralty jurisdiction over claims against the maritime actor.

## Decision

- The Supreme Court affirmed the court of appeals and held that the federal district court had admiralty jurisdiction over Great Lakes’s Limitation Act suit.
- The location test was satisfied because the alleged negligence occurred from a vessel on navigable waters and the land-based damage was alleged to have been caused by that vessel.
- The Court rejected a separate “nonremoteness” jurisdictional requirement; the statutory “caused by” inquiry turns on proximate cause, not temporal or geographic immediacy.
- The connection test was satisfied because the incident type—vessel-caused damage to an underwater structure—has the potential to disrupt maritime commerce.
- The activity giving rise to the incident—operating a barge to perform riverbed pile-driving—bore a substantial relationship to traditional maritime activity.
- The involvement of non-maritime parties did not negate admiralty jurisdiction over the maritime party; additional claims and parties remain subject to ordinary supplemental-jurisdiction and impleader analysis.

## Legal Principles

- Admiralty tort jurisdiction requires both:
  - A location showing that the tort occurred on navigable waters, or that land injury was caused by a vessel on navigable waters.
  - A connection showing (i) the incident type has a potentially disruptive impact on maritime commerce and (ii) the relevant activity is substantially related to traditional maritime activity.
- For land-based damage alleged to be “caused by a vessel on navigable water,” the governing standard is proximate causation rather than physical or temporal closeness.
- The “general features” of the incident and the “character of the activity” must be assessed at an intermediate level of generality, not by focusing on highly particular local circumstances.
- The existence of both maritime and non-maritime tortfeasors does not eliminate admiralty jurisdiction over claims against a maritime defendant whose conduct satisfies the jurisdictional tests.

## Conclusion

The Court held that the Chicago River flooding claims fell within federal admiralty tort jurisdiction because the alleged negligence occurred from a vessel on navigable waters, the land-based damages were proximately caused by that vessel, and the incident type and vessel operations were sufficiently connected to maritime commerce and traditional maritime activity.


Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., 513 U.S. 527 (1995)