Executive Jet Aviation, Inc., et al. v. City of Cleveland, et al.

Supreme Court of United States
409 U.S. 249 (1972)

ELI5:

Rule of Law:

For a tort claim to be cognizable under federal admiralty jurisdiction, the alleged wrong must not only occur on or over navigable waters (maritime locality) but must also bear a significant relationship to traditional maritime activity (maritime nexus).

Facts:

On July 28, 1968, a jet aircraft owned by Executive Jet Aviation, Inc. was taking off from Burke Lakefront Airport in Cleveland, Ohio, an airport adjacent to Lake Erie.
The flight was a charter scheduled to fly from Cleveland to Portland, Maine, and then to White Plains, New York.
During takeoff, the jet struck a flock of seagulls, which were ingested into its engines, causing an almost total loss of power.
The disabled plane struck a perimeter fence and a truck before settling in the navigable waters of Lake Erie, a short distance from the runway.
The aircraft subsequently sank and was a total loss.

Procedural Posture:

Executive Jet Aviation, Inc. (petitioner) sued the City of Cleveland, the airport manager, and an air traffic controller (respondents) in the U.S. District Court for the Northern District of Ohio, invoking federal admiralty jurisdiction.
The District Court dismissed the complaint for lack of subject matter jurisdiction, finding the suit was not cognizable in admiralty.
Executive Jet Aviation, Inc., as appellant, appealed the dismissal to the U.S. Court of Appeals for the Sixth Circuit.
The Court of Appeals affirmed the District Court's judgment, holding that the alleged tort occurred on land before the aircraft reached Lake Erie.
The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.

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Issue:

Does federal admiralty jurisdiction extend to an aviation tort claim where a land-based aircraft on a domestic flight crashes into navigable waters within a state's territory?

Opinions:

Majority - Justice Stewart

No. Federal admiralty jurisdiction does not extend to an aviation tort claim merely because the aircraft crashed into navigable waters; the wrong must also bear a significant relationship to traditional maritime activity. The historical test for admiralty tort jurisdiction focused exclusively on the locality of the wrong, which has proven problematic and can lead to absurd results, especially in aviation cases where the connection to water can be purely fortuitous. Relying on locality alone would make jurisdiction dependent on the arbitrary circumstance of where a plane happens to fall. Therefore, the Court establishes a new, two-part test requiring both maritime locality and a maritime nexus. In this case, the flight of a land-based aircraft between two points in the continental United States has no significant relationship to traditional maritime activity such as navigation or commerce on navigable waters. The concepts and rules of admiralty law are wholly alien to air commerce, and the crash's connection to Lake Erie was merely incidental.

Analysis:

This landmark decision fundamentally altered admiralty tort jurisdiction by rejecting the strict, centuries-old locality test in favor of a new 'locality plus nexus' standard for aviation torts. By requiring a significant relationship to traditional maritime activity, the Court narrowed the scope of admiralty jurisdiction, preventing federal courts from hearing cases with only a fortuitous connection to navigable waters. This ruling ensures that admiralty law, with its unique substantive rules, is reserved for disputes genuinely maritime in character, and it has influenced the analysis of admiralty jurisdiction across all tort cases, not just those involving aircraft.

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