Foremost Insurance v. Richardson
457 US 668, 1982 U.S. LEXIS 40, 73 L. Ed. 2d 300 (1982)
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Rule of Law:
Federal admiralty jurisdiction extends to tort claims arising from the collision of non-commercial vessels on navigable waters, as the navigation of vessels itself bears a significant relationship to traditional maritime activity.
Facts:
- Two pleasure boats collided on the Amite River in Louisiana, a navigable waterway.
- One boat was being used for water skiing at the time of the accident.
- The other boat was a bass boat being used exclusively for pleasure fishing.
- Clyde Richardson, an occupant of one of the boats, was killed in the collision.
- Neither boat had ever been used for any commercial maritime activity before the accident.
- At the time of the accident, none of the occupants on either boat were engaged in any commercial activity, nor were the operators being paid.
Procedural Posture:
- The wife and children of Clyde Richardson (respondents) filed a wrongful death action against Shirley Eliser and Foremost Insurance Co. (petitioners) in the U.S. District Court for the Middle District of Louisiana.
- Jurisdiction was asserted under federal admiralty and maritime jurisdiction.
- Petitioners filed a motion to dismiss for lack of subject-matter jurisdiction, arguing the collision of two pleasure boats did not fall within admiralty jurisdiction.
- The District Court granted the motion to dismiss, finding that the lack of commercial maritime activity was fatal to the jurisdictional claim.
- Respondents appealed the dismissal to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals reversed the District Court, holding that a collision between two boats on navigable waters, regardless of their purpose, bears a sufficient relationship to traditional maritime activity.
- The U.S. Supreme Court granted certiorari to resolve confusion in the lower courts.
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Issue:
Does federal admiralty jurisdiction under 28 U.S.C. § 1333 extend to a tort claim arising from the collision of two non-commercial pleasure boats on navigable waters?
Opinions:
Majority - Justice Marshall
Yes. Federal admiralty jurisdiction extends to a tort claim arising from the collision of two non-commercial pleasure boats on navigable waters. The requirement that the wrong bear a significant relationship to traditional maritime activity does not mean the activity must be commercial. The federal interest in protecting maritime commerce is served by subjecting all operators of vessels on navigable waters to uniform rules of conduct, such as the navigational 'Rules of the Road.' The potential disruptive impact of any collision on maritime commerce, coupled with the traditional concern of admiralty law for navigation, is sufficient to establish a significant relationship to traditional maritime activity, regardless of the vessels' use for pleasure or commerce.
Dissenting - Justice Powell
No. Federal admiralty jurisdiction should not extend to a tort claim arising from the collision of two non-commercial pleasure boats. The majority's decision misconstrues the holding of Executive Jet, as the historical purpose of admiralty jurisdiction has always been to address matters of maritime commerce. This accident between two small pleasure boats has no connection to any historic federal admiralty interest. Extending jurisdiction here is an unnecessary and purposeless expansion of federal authority at the expense of state tort law and state-court jurisdiction, furthering an erosion of federalism without serving any substantial federal interest.
Analysis:
This decision significantly clarifies the 'nexus' requirement for admiralty tort jurisdiction established in Executive Jet Aviation, Inc. v. City of Cleveland. By holding that non-commercial maritime activity can satisfy the 'significant relationship to traditional maritime activity' test, the Court greatly expanded the scope of federal admiralty jurisdiction to include the vast majority of recreational boating accidents on navigable waters. This expansion ensures the application of uniform federal maritime law, preempting state tort law in such cases, but also increases the caseload of federal courts with matters previously considered purely local.
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