## Facts

- Southern Pacific Company, an interstate rail carrier, also owned and operated a steamship engaged in interstate maritime transportation.
- Christen Jensen, a stevedore employed by Southern Pacific, loaded and unloaded cargo by driving an electric freight truck between the vessel and a pier in New York.
- While the vessel was berthed at a New York pier in navigable waters, Jensen was fatally injured as he backed a loaded truck out of the ship and struck part of the vessel.
- New York’s workers’ compensation agency awarded benefits to Jensen’s dependents under the New York Workmen’s Compensation Act.
- New York appellate courts affirmed the award.
- Southern Pacific challenged the statute’s application as unconstitutional under federal admiralty and maritime jurisdiction principles.

## Issues

1. Whether a state workers’ compensation statute may constitutionally govern an injury and death sustained by a stevedore while working on a vessel in navigable waters.
2. What limits the Constitution places on state laws that alter rights, liabilities, or remedies within federal admiralty and maritime jurisdiction.

## Decision

- The Supreme Court reversed and set aside the compensation award.
- The Court held the New York Workmen’s Compensation Act unconstitutional as applied to Jensen’s maritime injury and death.
- The Court concluded stevedoring aboard a ship in navigable waters is maritime employment, and resulting rights and liabilities fall within admiralty jurisdiction.
- The Court rejected reliance on the Federal Employers’ Liability Act, holding it did not extend to this independent maritime transportation merely because the vessel was owned by a railroad.

## Legal Principles

- Congress has paramount authority to determine maritime law applicable throughout the United States; in the absence of controlling federal statutes, federal courts apply the general maritime law as national law within admiralty jurisdiction.
- State law affecting maritime matters is invalid to the extent it (1) contravenes the essential purpose of an act of Congress, (2) materially prejudices characteristic features of general maritime law, or (3) interferes with the harmony and uniformity of maritime law in its interstate and international relations.
- A state may not replace maritime remedies with a no-fault, administratively administered compensation scheme when doing so materially alters characteristic maritime-law features and disrupts uniformity.

## Conclusion

The Court invalidated New York’s application of its workers’ compensation statute to a stevedore’s death on navigable waters, reasoning that maritime injuries and remedies fall within federal admiralty jurisdiction and require national uniformity that state compensation schemes may not materially disturb.


S. Pac. Co. v. Jensen, 244 U.S. 205 (1917)