The Moses Taylor
18 L. Ed. 397, 4 Wall. 411, 71 U.S. 411 (1867)
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Rule of Law:
Under the U.S. Constitution and the Judiciary Act of 1789, federal courts have exclusive jurisdiction over admiralty and maritime cases prosecuted as in rem proceedings. State statutes that purport to grant state courts jurisdiction over such in rem actions are unconstitutional.
Facts:
- Marshall O. Roberts owned the steamship Moses Taylor, a vessel of over one thousand tons burden used for carrying passengers and freight between Panama and San Francisco.
- In October 1863, a passenger entered into a contract with Roberts for transportation from New York to San Francisco for a fee of one hundred dollars.
- The contract stipulated that the passenger would be transported on the Moses Taylor for the Pacific Ocean portion of the voyage, from Panama to San Francisco.
- The passenger alleged that Roberts breached the contract by failing to provide reasonable despatch, proper food, water, and lodging during the voyage.
Procedural Posture:
- The passenger filed an in rem action against the steamship Moses Taylor in a California Justice of the Peace court, seeking damages under a state statute.
- The ship's agent appeared and objected to the court's jurisdiction, arguing the cause was exclusively within federal admiralty jurisdiction.
- The Justice of the Peace overruled the objection and rendered judgment for the passenger.
- The defendant appealed to the County Court, which tried the case de novo.
- In the County Court, the defendant again raised the jurisdictional objection, which was again overruled, and judgment was again rendered for the passenger.
- As the judgment amount was too small for an appeal to the California Supreme Court, the County Court was the highest state court with jurisdiction over the matter.
- The owner of the Moses Taylor then brought the case to the U.S. Supreme Court on a writ of error.
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Issue:
Does a California state statute, which authorizes an in rem proceeding against a vessel for breach of a maritime contract, conflict with the U.S. Constitution's grant of exclusive admiralty and maritime jurisdiction to the federal courts?
Opinions:
Majority - Mr. Justice Field
Yes. The California statute, to the extent it authorizes actions in rem against vessels for causes of action cognizable in admiralty, unconstitutionally encroaches upon the exclusive jurisdiction of the federal courts. The contract for passenger transportation on the high seas is a maritime contract, placing the case squarely within federal admiralty jurisdiction as granted by Article III of the Constitution. The Judiciary Act of 1789 validly vested this jurisdiction exclusively in the federal district courts. The proceeding authorized by the California statute is an action in rem—a suit against the vessel itself—which is the characteristic and distinguishing feature of an admiralty suit, not a common law remedy. The 'saving to suitors' clause of the Judiciary Act preserves only common-law remedies, and an in rem action is a civil-law remedy, not a common-law one. Therefore, the state court lacked jurisdiction to hear the case.
Analysis:
This case is a landmark decision that solidifies the exclusive nature of federal admiralty jurisdiction for in rem proceedings. It clarifies that the 'saving to suitors' clause does not allow state courts to entertain admiralty-style actions directly against a vessel. The decision ensures national uniformity in maritime law by preventing states from creating their own parallel systems of admiralty justice. It firmly establishes the jurisdictional line between state common-law courts and federal admiralty courts, confirming that the type of remedy sought (in rem vs. in personam) is a critical factor in the jurisdictional analysis.
