Facts
- Francisco Romero, a Spanish seaman, served aboard the S.S. Guadalupe, a Spanish-flag vessel owned by a Spanish corporation, for a voyage that began and ended in Spain.
- While the vessel was docked in Hoboken, New Jersey, Romero was seriously injured on deck when struck by a cable during cargo-related operations.
- A New York husbanding agent arranged, by oral contracts, for a stevedore and a carpentry contractor to perform work aboard the vessel in Hoboken.
- Romero sued on the law side of federal district court to obtain a jury trial, asserting a Jones Act negligence claim and general maritime claims (including unseaworthiness and maintenance and cure) against the shipowner and agent, and maritime negligence claims against the stevedore and carpentry contractor.
- The district court dismissed the action; the court of appeals affirmed; the Supreme Court reviewed.
Issues
- Whether alleging a Jones Act claim suffices to invoke federal jurisdiction even if the Act ultimately provides no substantive remedy on the facts alleged.
- Whether 28 U.S.C. § 1331 provides law-side federal-question jurisdiction over claims based solely on general maritime law.
- Whether the district court could hear general maritime claims against the foreign shipowner as pendent to the Jones Act claim.
- Whether 28 U.S.C. § 1332 supplies diversity jurisdiction for general maritime negligence claims against domestic corporate defendants.
- Whether the Jones Act or United States general maritime law applies to a foreign seaman’s claims against a foreign shipowner arising from an injury in a United States port.
Decision
- The Supreme Court vacated the judgment and remanded for further proceedings.
- The Court held that Jones Act jurisdiction was adequately alleged; the lower court erred by treating failure on the merits as lack of jurisdiction.
- The Court held § 1331 does not grant law-side jurisdiction over claims resting only on general maritime law.
- The Court held the district court had pendent jurisdiction, attached to the Jones Act claim, to consider related general maritime claims against the foreign shipowner.
- The Court held there was diversity jurisdiction under § 1332 over general maritime negligence claims against the domestic corporate defendants.
- On choice of law, the Court held neither the Jones Act nor United States general maritime law governed Romero’s claims against the foreign shipowner given the predominance of foreign contacts.
- The Court approved dismissal of unseaworthiness and maintenance-and-cure claims against the husbanding agent based on the trial court’s factual findings.
- The Court remanded for consideration of the negligence claims against the domestic corporate defendants.
Legal Principles
- A complaint’s colorable invocation of a federal statute (such as the Jones Act) generally supports subject-matter jurisdiction, even if the claim fails on the merits.
- General maritime law claims do not “arise under” the Constitution or laws of the United States within the meaning of 28 U.S.C. § 1331 when brought on the law side.
- Admiralty and maritime jurisdiction is a distinct jurisdictional grant; law-side adjudication of maritime claims requires an independent basis such as diversity or a statutory cause of action.
- Federal courts may exercise pendent jurisdiction over closely related nonstatutory maritime claims when anchored to a properly invoked federal statutory claim.
- Diversity jurisdiction can support law-side maritime tort claims against diverse defendants, including suits by an alien against domestic corporations.
- For a foreign seaman’s claims against a foreign shipowner, choice of law turns on factors including the law of the flag, the parties’ allegiance, the place of contract, and the center of the employment relationship; predominant foreign contacts can defeat application of the Jones Act and United States maritime law.
Conclusion
The Court clarified that general maritime law does not itself create § 1331 federal-question jurisdiction on the law side, distinguished jurisdiction from the existence of a substantive Jones Act remedy, applied choice-of-law limits to bar Jones Act and United States maritime law claims against a foreign shipowner on largely foreign facts, and remanded to allow negligence claims against diverse domestic defendants to proceed.