## Facts

- A federally documented fishing vessel based in San Diego was owned by multiple co-owners with undivided interests.
- Eight co-owners holding an aggregate 85% interest filed an action in California Superior Court seeking sale of the vessel and partition of the sale proceeds under a California statute.
- The remaining co-owner, Manuel Madruga (15%), was personally served and objected that only a federal district court sitting in admiralty could order sale and partition of a documented vessel.
- The state trial court concluded it had jurisdiction; the California Supreme Court denied a writ of prohibition that would have stopped the action.
- The U.S. Supreme Court granted review to determine whether the state court lacked jurisdiction due to federal admiralty authority.

## Issues

1. Whether federal district courts have admiralty jurisdiction to order sale of a vessel and partition of proceeds among co-owners.
2. If so, whether that admiralty jurisdiction is exclusive such that a state court lacks power to adjudicate a co-owner partition action.
3. Whether denial of a writ of prohibition by the state supreme court is a final judgment reviewable by the U.S. Supreme Court.

## Decision

- The Court affirmed the judgment of the California Supreme Court.
- Federal district courts possess admiralty jurisdiction to order a vessel sold for partition and to distribute proceeds among co-owners.
- That admiralty jurisdiction is not exclusive as to this type of controversy because the state action was not a proceeding in rem.
- The California partition action was an in personam dispute among identified co-owners over whom the state court had personal jurisdiction, and it did not purport to bind the world at large.
- The denial of the writ of prohibition was a final, reviewable judgment on the jurisdictional issue.

## Legal Principles

- Federal district courts have admiralty jurisdiction to order sale of a vessel and partition of the proceeds among owners.
- Federal admiralty jurisdiction is exclusive primarily for maritime causes pursued as proceedings in rem; in personam maritime disputes may be heard in state court when the state forum is otherwise competent.
- A state court’s in personam adjudication among co-owners, based on personal service and limited to their interests, is not barred merely because the vessel is federally documented.
- A state high court’s definitive rejection of a jurisdictional challenge via prohibition can constitute a final judgment for U.S. Supreme Court review.

## Conclusion

The Supreme Court held that although federal courts have admiralty power to order sale and partition of a vessel, that power does not bar a state court from adjudicating an in personam partition action among co-owners; because the state proceeding did not operate in rem, the California courts could proceed.


Madruga v. Superior Court, 346 U.S. 556 (1954)