## Facts

- James F. Lewis, a deckhand, alleged he was injured aboard the M/V *Karen Michelle* when he tripped over a wire.
- Lewis sued the vessel owner, Lewis & Clark Marine, Inc., in Illinois state court under the Jones Act and related maritime theories.
- The vessel owner filed a federal limitation action seeking exoneration from, or limitation of, liability under the Limitation of Liability Act.
- The federal district court approved a limitation fund (secured by a surety bond) and enjoined other proceedings, staying the state case.
- Lewis moved to dissolve the injunction and stipulated that he was the sole claimant, his claim did not exceed the limitation fund, and the owner’s limitation rights would be preserved (including waiver of any res judicata effect on limitation issues).

## Issues

1. Whether the district court abused its discretion by dissolving the Limitation of Liability Act injunction and allowing the seaman’s state-court action to proceed.
2. How the Limitation of Liability Act’s concursus/injunction procedure should be reconciled with the saving-to-suitors clause in a single-claimant or adequate-fund setting.

## Decision

- The Supreme Court unanimously reversed the Eighth Circuit.
- The Court held the district court did not abuse its discretion in dissolving the injunction.
- The Court reinstated the order permitting the state-court action to proceed while the federal court retained jurisdiction to protect the shipowner’s statutory right to limitation.

## Legal Principles

- The saving-to-suitors clause preserves state-court remedies and concurrent jurisdiction over certain maritime claims; it must be harmonized with the Limitation of Liability Act.
- A Limitation Act injunction is not automatic or absolute; district courts may lift it when doing so will not impair the shipowner’s right to limitation.
- In single-claimant and adequate-fund situations, protective stipulations and retained federal jurisdiction can sufficiently safeguard the shipowner’s limitation rights while allowing state litigation.
- The Limitation of Liability Act protects the right to limit liability; it does not guarantee a shipowner a federal forum for exoneration or for adjudication of all liability issues.
- Access to a state forum is a preserved remedy under the saving-to-suitors clause and does not depend on a claimant’s demand for a jury trial.

## Conclusion

The Court held that a district court may dissolve a Limitation of Liability Act injunction and allow a state-court maritime personal injury action to proceed when the claimant’s stipulations and the federal court’s retained jurisdiction adequately protect the vessel owner’s right to limitation.


Lewis v. Lewis & Clark Marine, Inc., 531 U.S. 438 (2001)