Gillespie v. United States Steel Corp.
379 U.S. 148, 1964 U.S. LEXIS 2159, 13 L. Ed. 2d 199 (1964)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The Jones Act provides the exclusive remedy for a seaman's death occurring in the course of employment, superseding state wrongful death statutes and precluding claims based on unseaworthiness under general maritime law.
Facts:
- Daniel Gillespie was a seaman employed by the respondent shipowner.
- While working on the respondent's ship docked in Ohio, Gillespie fell overboard and drowned.
- His mother, acting as the administratrix of his estate, alleged that Gillespie suffered pain and anguish before his death.
- Gillespie was survived by his mother and his dependent brother and sisters.
Procedural Posture:
- Petitioner, as administratrix of her son's estate, filed suit against the respondent shipowner in federal District Court.
- The respondent filed a motion to strike all claims based on the Ohio wrongful death statute, unseaworthiness, and claims for the benefit of the decedent's siblings.
- The District Court granted the respondent's motion to strike.
- Petitioner appealed the District Court's order to the U.S. Court of Appeals.
- Respondent moved to dismiss the appeal, arguing the order was not a 'final decision' and thus not appealable.
- Petitioner also filed a petition for a writ of mandamus in the Court of Appeals.
- The Court of Appeals affirmed the District Court's order on the merits without definitively ruling on its appealability.
- The U.S. Supreme Court granted certiorari to review the Court of Appeals' judgment.
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 the Jones Act provide the exclusive remedy for a seaman's death, thereby preempting state wrongful death statutes and claims for unseaworthiness under general maritime law?
Opinions:
Majority - Mr. Justice Black
Yes, the Jones Act provides the exclusive right of action for the death of seamen killed in the course of their employment. The Court reaffirms its 34-year-old precedent in Lindgren v. United States, which held that Congress passed the Jones Act to create a uniform, national remedy for seamen, thereby superseding all state death statutes. Because Congress has not acted to change this interpretation, the Court declines to overrule it. The Court also affirms that the Jones Act incorporates the Federal Employers' Liability Act's (FELA) three-tiered, alternative beneficiary structure, meaning a living parent's claim precludes a claim by the decedent's siblings. While the claim for pain and suffering based on unseaworthiness and a state survival statute should not have been dismissed on the pleadings, the core holding that the Jones Act is the exclusive remedy for death is upheld. The Court also held that the Court of Appeals correctly exercised jurisdiction by giving the finality requirement a 'practical rather than a technical construction' to avoid the danger of denying justice by delay.
Dissenting - Mr. Justice Goldberg
No, the Jones Act should not preempt a state-law-based claim for unseaworthiness. The dissent argues that the portion of Lindgren relied upon by the majority was non-binding dictum and that subsequent cases have undermined its reasoning by allowing unseaworthiness claims for non-fatal injuries. It is an unjust anomaly to allow recovery for unseaworthiness for injuries but not for death. The dissent contends that Congress intended the Jones Act to supplement, not eliminate, existing maritime remedies, and that stare decisis does not require adhering to an irrational doctrine that denies a humane and justifiable remedy.
Dissenting - Mr. Justice Harlan
This opinion does not answer the substantive issue question. The dissent argues that the Court of Appeals lacked jurisdiction because the District Court's order striking parts of the complaint was not a 'final decision' under 28 U.S.C. § 1291. Tolerating such 'piecemeal litigation' undermines the purpose of the finality rule. The case should be vacated and remanded with instructions to dismiss the appeal for lack of jurisdiction, as the majority's 'practical' approach is an unsatisfactory justification for departing from clear jurisdictional requirements.
Analysis:
This case solidifies the doctrine that the Jones Act is the exclusive remedy for a seaman's death, reaffirming the precedent set in Lindgren. The decision creates a uniform federal scheme but also perpetuates a noted anomaly in maritime law, where the remedies available for a seaman's death are narrower than those for a non-fatal injury. Procedurally, the Court's 'practical' approach to the final judgment rule in 28 U.S.C. § 1291 introduces flexibility, allowing appellate courts to hear appeals from 'marginal' non-final orders to prevent injustice, potentially weakening the traditionally strict application of the rule.
Unlock the full brief for Gillespie v. United States Steel Corp.