Lewis v. Lewis & Clark Marine, Inc.

Last updated
Lewis v. Lewis & Clark Marine, Inc.
Seal of the United States Supreme Court.svg
Argued November 29, 2000
Decided February 21, 2001
Full case nameJames F. Lewis v. Lewis & Clark Marine Incorporated
Citations 531 U.S. 438 ( more )
121 S. Ct. 993; 148 L. Ed. 2d 931
Prior history On Writ of Certiorari to the United States Court of Appeals for the Eighth Circuit
Holding
A District Court did not abuse discretion when it dissolved an injunction under the LLA, which prevented a seaman from suing a vessel owner in state court.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
David Souter  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Case opinions
Majority O'Connor, joined by unanimous
Laws applied
Limitation of Liability Act

Lewis v. Lewis & Clark Marine, Inc., 531 U.S. 438 (2001), was a decision by the Supreme Court of the United States involving an injunction under the Limitation of Liability Act and whether a district court acted properly in dissolving it.

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Contents

Background

In 1998, James F. Lewis, a deckhand aboard a ship owned by Lewis & Clark Marine, Inc., claimed that he was injured when he tripped over a wire on the boat. Lewis then sued Lewis & Clark in Illinois County Court, for personal injuries claiming negligence under the Jones Act. Lewis & Clark had already filed a complaint for exoneration from, or limitation of, liability in the District Court under the Limitation of Liability Act (Act). Subsequently, the court approved a surety bond of $450,000, representing Lewis & Clark's interest in the vessel, ordered that any claim related to the incident be filed with the court within a specified period, and enjoined the filing or prosecution of any suits related to the incident. The injunction prevented Lewis from litigating his personal injury claims in state court and he moved to dissolve it. Ultimately, the court dissolved the injunction. The Eight Circuit Court of Appeals reversed. [1]

Illinois State of the United States of America

Illinois is a state in the Midwestern and Great Lakes region of the United States. It has the fifth largest gross domestic product (GDP), the sixth largest population, and the 25th largest land area of all U.S. states. Illinois is often noted as a microcosm of the entire United States. With Chicago in northeastern Illinois, small industrial cities and immense agricultural productivity in the north and center of the state, and natural resources such as coal, timber, and petroleum in the south, Illinois has a diverse economic base, and is a major transportation hub. Chicagoland, Chicago's metropolitan area, encompasses over 65% of the state's population. The Port of Chicago connects the state to international ports via two main routes: from the Great Lakes, via the Saint Lawrence Seaway, to the Atlantic Ocean and from the Great Lakes to the Mississippi River, via the Illinois Waterway to the Illinois River. The Mississippi River, the Ohio River, and the Wabash River form parts of the boundaries of Illinois. For decades, Chicago's O'Hare International Airport has been ranked as one of the world's busiest airports. Illinois has long had a reputation as a bellwether both in social and cultural terms and, through the 1980s, in politics.

Opinion of the Court

Justice Sandra Day O'Connor wrote the unanimous opinion of the Court which reversed the Eighth Circuit's decision. [2] The Court held that because state courts may adjudicate claims like Lewis' against vessel owners so long as the owner's right to seek limitation of liability is protected, the Court of Appeals erred in reversing the District Court's decision to dissolve the injunction. Writing for the Court, Justice O'Connor rejected the respondent's proposal to make "run of the mill personal injury actions involving vessels a matter of exclusive federal jurisdiction except where the claimant happens to seek a jury trial." [3]

Sandra Day OConnor Former Associate Justice of the Supreme Court of the United States

Sandra Day O'Connor is a retired Associate Justice of the Supreme Court of the United States, who served from her appointment in 1981 by President Ronald Reagan until her retirement in 2006. She was the first woman to serve on the Court.

Jurisdiction is the practical authority granted to a legal body to administer justice within a defined field of responsibility, e.g., Michigan tax law. In federations like the United States, areas of jurisdiction apply to local, state, and federal levels; e.g. the court has jurisdiction to apply federal law.

See also

Merchant Marine Act of 1920 legislation

The Merchant Marine Act of 1920 is a United States federal statute that provides for the promotion and maintenance of the American merchant marine. Among other purposes, the law regulates maritime commerce in U.S. waters and between U.S. ports. Section 27 of the Merchant Marine Act is known as the Jones Act and deals with cabotage and requires that all goods transported by water between U.S. ports be carried on U.S.-flag ships, constructed in the United States, owned by U.S. citizens, and crewed by U.S. citizens and U.S. permanent residents. The act was introduced by Senator Wesley Jones. The law also defines certain seaman's rights.

Personal injury is a legal term for an injury to the body, mind or emotions, as opposed to an injury to property.

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References

  1. Lewis vs. Lewis & Clark Marine, Inc., 531 U.S. 438, 442-44 (2001).
  2. 531 U.S. 438 at 449.
  3. 531 U.S. 438 at 456.
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