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American Dredging Co. v. Miller

510 U.S. 443, 114 S. Ct. 981, 127 L. Ed. 2d 285 (1994)

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American Dredging Co. v. Miller

United States Supreme Court

510 U.S. 443, 114 S. Ct. 981, 127 L. Ed. 2d 285 (1994)

Facts

William Robert Miller (plaintiff) was injured while working on a tugboat owned by American Dredging Company (defendant) in the Delaware River. Miller sued American Dredging in Louisiana state court, requesting relief pursuant to both the Jones Act and general maritime law. The Jones Act, over which federal and state courts have concurrent jurisdiction, allows a seaman injured in the course of his employment to sue for damages. American Dredging moved to dismiss the case under the doctrine of forum non conveniens. The trial court granted the motion, reasoning that federal maritime law required it to apply the doctrine. The Louisiana Court of Appeal affirmed. The Louisiana Supreme Court reversed, holding that Louisiana state law made the doctrine of forum non conveniens unavailable in maritime cases filed in Louisiana courts and that federal maritime law did not preempt the state law. On appeal, American Dredging relied on Southern Pacific Co. v. Jensen, 244 U.S. 205 (1917), to support its argument that federal maritime law preempted Louisiana’s law. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Scalia, J.)

Concurrence (Stevens, J.)

Concurrence (Souter, J.)

Dissent (Kennedy, J.)

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