Chelentis v. Luckenbach S. S. Co.
247 U.S. 372, 38 S. Ct. 501 (1918)
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Rule of Law:
Under general maritime law, a seaman who suffers injury in the course of service due to the negligence of the master or another member of the crew is limited to the remedy of maintenance and cure. This substantive rule applies even when the seaman brings an action in a common law court under the Judiciary Act's "saving to suitors" clause.
Facts:
- In December 1915, petitioner Chelentis was employed as a fireman by respondent Luckenbach S.S. Co. aboard the steamship 'J. L. Luckenbach'.
- While the vessel was at sea during a heavy wind, Chelentis was ordered to perform duties on deck.
- A large wave came aboard, knocking Chelentis down and breaking his leg.
- As a consequence of the injury, Chelentis's leg required amputation.
- Chelentis alleged that his injury resulted from a negligent and 'improvident order' given by a superior officer.
- The seaworthiness of the ship and its appliances was not in dispute.
Procedural Posture:
- Chelentis (plaintiff) filed a common law action against Luckenbach S.S. Co. (defendant) in the Supreme Court of New York County, a state trial court.
- The case was removed by the defendant to the United States District Court for the Southern District of New York (federal trial court) based on diversity of citizenship.
- At trial, the District Court directed a verdict for the defendant, Luckenbach.
- Chelentis (appellant) appealed the judgment to the U.S. Circuit Court of Appeals for the Second Circuit (intermediate appellate court).
- The Circuit Court of Appeals affirmed the District Court's judgment.
- The petitioner, Chelentis, appealed to the U.S. Supreme Court.
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Issue:
Does the "saving to suitors" clause of the Judiciary Act of 1789 or the Seamen's Act of 1915 permit a seaman injured by the negligence of a superior officer to recover full indemnity damages under common law, rather than being limited to the traditional maritime remedy of maintenance and cure?
Opinions:
Majority - Mr. Justice McReynolds
No. A right sanctioned by the maritime law may be enforced through any appropriate remedy recognized at common law, but this does not give a party an election to determine whether the defendant’s liability shall be measured by common-law standards rather than those of the maritime law. The 'saving to suitors' clause preserves common law remedies, but not common law rights; it does not authorize state courts to apply substantive common law rules that would interfere with the uniform application of maritime law. The traditional maritime rule, as established in The Osceola, holds that a seaman cannot recover indemnity for the negligence of the master or a crew member; the sole remedy is maintenance and cure. The Seamen’s Act of 1915, which abolished the fellow-servant doctrine for seamen, is irrelevant because under maritime law, liability for maintenance and cure existed regardless of that doctrine, and the Act did not express an intent to create a new cause of action for full indemnity for negligence.
Concurring - Mr. Justice Holmes
Concurred in the result without a written opinion.
Dissenting - Mr. Justice Pitney, Mr. Justice Brandeis and Mr. Justice Clarke
Dissented without a written opinion.
Analysis:
This decision strongly affirms the principle of uniformity in general maritime law, establishing that its substantive rules govern seamen's injury claims regardless of the forum. By narrowly interpreting the "saving to suitors" clause as preserving only remedies and not substantive rights, the Court prevented state common law from creating divergent standards of liability for shipowners. This ruling solidified the limited nature of a seaman's recovery for negligence, distinguishing it sharply from land-based employment torts and directly leading to legislative action by Congress, which passed the Jones Act in 1920 to grant seamen a statutory right to sue for negligence.
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