Garrett v. Moore-McCormack Co.
63 S. Ct. 246, 317 U.S. 239 (1942)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
When a state court adjudicates a cause of action created by federal maritime law, it must apply federal substantive law, including the admiralty rule that places the burden of proof on the defendant to show that a seaman's release was executed freely, without deception or coercion, and with a full understanding of his rights.
Facts:
- Garrett, a seaman, was injured while working for Moore-McCormack Co. on a vessel.
- Garrett claimed his injury was caused by a hatch cover falling on him due to the company's negligence.
- Moore-McCormack Co. contended that Garrett's serious injuries, if any, were caused by a fight or prior accidents.
- Several days after returning to the United States, Garrett signed a document releasing Moore-McCormack Co. from all claims in exchange for $100.
- Garrett asserted that he signed the release while under the influence of pain medication and was threatened with imprisonment if he did not sign.
- Garrett also believed the $100 was a payment for wages owed, not a settlement of his injury claim.
- Moore-McCormack Co. maintained that the $100 was a full settlement, Garrett was not impaired, and no threats were made.
Procedural Posture:
- Garrett filed suit against Moore-McCormack Co. in a Pennsylvania state trial court for damages under the Jones Act and for maintenance and cure.
- A jury returned a verdict in favor of Garrett.
- Moore-McCormack Co. filed a motion for judgment non obstante veredicto (JNOV).
- The state trial court, sitting en banc, granted the JNOV for Moore-McCormack Co., finding that Garrett failed to meet Pennsylvania's high burden of proof for invalidating a written release.
- Garrett appealed to the Supreme Court of Pennsylvania.
- The Supreme Court of Pennsylvania affirmed the trial court's judgment, holding that the burden of proof was a procedural issue governed by state law.
- The United States Supreme Court granted certiorari to review the decision of the Supreme Court of Pennsylvania.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state court, when adjudicating a seaman's claim under the Jones Act, unacceptably alter the seaman's substantive federal rights by applying a state procedural rule that places the burden on the seaman to invalidate a release, rather than the federal admiralty rule which places the burden on the defendant to validate it?
Opinions:
Majority - Mr. Justice Black
Yes. When a state court adjudicates a federal maritime claim, it is required to apply federal substantive law, and the admiralty rule governing the burden of proof for a seaman's release is a substantive right, not a mere procedural rule. The court reasoned that rights created by the Jones Act must be uniformly applied nationwide. The historic admiralty doctrine treats seamen as 'wards of the admiralty,' affording them special protection. This protection includes a rule that places the burden of proof on the party seeking to enforce a seaman's release. The defendant must show the release was executed freely, without deception, and with the seaman's full understanding of his rights. The Pennsylvania rule, which required the seaman to prove the release's invalidity by 'clear, precise, and indubitable' evidence, impermissibly diminished the substantive rights granted to the seaman by federal law.
Analysis:
This case is a foundational example of the 'reverse-Erie' doctrine, establishing that state courts must apply federal substantive law when enforcing federally created rights. The decision clarifies that certain rules, such as the burden of proof in this context, are so intertwined with the right itself that they are considered substantive, not merely procedural. This ensures that federal statutory schemes, like the Jones Act, are applied uniformly across all states, preventing local rules from diluting federal protections and preserving the unique status of seamen as 'wards of the admiralty.'
Unlock the full brief for Garrett v. Moore-McCormack Co.