Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co.
130 L. Ed. 2d 1024, 513 U.S. 527, 1995 U.S. LEXIS 1622 (1995)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
For a tort claim to fall within federal admiralty jurisdiction, it must satisfy both a location test and a two-part connection test. The connection test requires that the incident has a potentially disruptive impact on maritime commerce and that the general character of the activity giving rise to the incident shows a substantial relationship to traditional maritime activity.
Facts:
- The City of Chicago hired Great Lakes Dredge and Dock Company to replace wooden pilings around bridge piers on the Chicago River, a navigable waterway.
- In August and September 1991, Great Lakes performed the work using a crane that sat on a barge anchored in the river.
- The work involved driving new pilings into the riverbed directly above a freight tunnel owned by the City of Chicago that ran under the river.
- Great Lakes's work allegedly weakened the structure of the tunnel.
- Approximately seven months later, on April 13, 1992, the tunnel wall collapsed.
- Water from the Chicago River flowed into the tunnel, subsequently flooding the basements of numerous buildings in downtown Chicago.
Procedural Posture:
- Victims of the Chicago flood, including Jerome B. Grubart, Inc., sued Great Lakes and the City of Chicago in Illinois state court.
- Great Lakes filed a separate lawsuit in the U.S. District Court (a federal trial court) seeking to limit its liability under federal admiralty law.
- The City of Chicago and Grubart filed a motion to dismiss Great Lakes's federal suit for lack of admiralty jurisdiction.
- The U.S. District Court granted the motion, dismissing the case.
- Great Lakes (as appellant) appealed to the U.S. Court of Appeals for the Seventh Circuit.
- The Seventh Circuit reversed the District Court, holding that admiralty jurisdiction existed.
- Jerome B. Grubart, Inc. and the City of Chicago (as petitioners) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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 federal admiralty jurisdiction extend to a tort claim for damages to land-based property, where the alleged tortious activity was conducted from a vessel on a navigable waterway and caused damage to an underwater structure, leading to the flooding?
Opinions:
Majority - Justice Souter
Yes. Federal admiralty jurisdiction extends to this tort claim because it satisfies both the location and connection tests. The location test is met because the injury on land was caused by a vessel on navigable water, as covered by the Extension of Admiralty Jurisdiction Act. The court rejects a strict temporal or spatial proximity rule in favor of a traditional proximate cause analysis. The claim also satisfies the two-pronged connection test from Sisson v. Ruby. First, the general incident—damage by a vessel to an underwater structure—has a potentially disruptive impact on maritime commerce, as it could (and did) lead to the closure of the waterway. Second, the general character of the activity giving rise to the incident—repair or maintenance work on a navigable waterway performed from a vessel—bears a substantial relationship to traditional maritime activity. The court clarified that this test is satisfied as long as one alleged tortfeasor was engaged in a traditional maritime activity that was a proximate cause of the incident.
Concurring - Justice O'Connor
Yes. This concurrence agrees with the majority's reasoning but writes to clarify a point on supplemental jurisdiction. Finding that admiralty jurisdiction exists over the claim against the maritime party (Great Lakes) does not automatically compel the court to exercise jurisdiction over all other claims and parties. A court must still conduct the standard inquiries for supplemental jurisdiction and impleader for any non-maritime parties, such as the City of Chicago.
Concurring - Justice Thomas
Yes. This opinion concurs in the judgment only, agreeing that jurisdiction exists but rejecting the majority's reasoning. The complicated, multifactor Sisson test is vague, unworkable, and a departure from a century of clearer precedent. The proper jurisdictional inquiry should be a simple, bright-line rule: whether the tort occurred on a vessel on the navigable waters of the United States. Since the alleged tort was caused by a vessel on the Chicago River, admiralty jurisdiction is proper without any need for the complex 'connection' analysis.
Analysis:
This case reaffirms and clarifies the two-part admiralty tort jurisdiction test established in Sisson v. Ruby. The decision solidifies that the test applies broadly, even to cases with significant land-based injuries and parties. Critically, it establishes that the 'substantial relationship' prong of the connection test can be satisfied by the activity of just one of multiple alleged tortfeasors. By rejecting a multifactor 'totality of the circumstances' test, the Court prioritized the existing framework, aiming to maintain relative predictability in determining admiralty jurisdiction.
Unlock the full brief for Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co.