Garrett v. Moore-McCormack Co.

Garrett (plaintiff) was a seaman who worked on transatlantic shipping vessels owned by Moore-McCormack Co. (defendant). Garrett was seriously injured while working on a Moore-McCormack vessel and spent a number of months in hospitals in Poland and the United States as a result. Within days of Garrett’s being brought back to the United States, Moore-McCormack presented Garrett with $100 in exchange for his signature on a release. Garrett sued Moore-McCormack in Pennsylvania court, under federal admiralty statutes, for negligence in causing his injuries. Moore-McCormack claimed that the $100 payment was paid to settle all claims arising from the accident and amounted to a full release by Garrett. Garrett claimed that he had been threatened into signing the release while under the influence of medication for his injuries and that the $100 had been payment for wages. The trial court held that because Garrett had brought the claim in state court rather than federal admiralty court, state procedural rules governed. Under Pennsylvania rules, Garrett bore the burden of attacking the validity of the signed release beyond a reasonable doubt. The jury found for Garrett. On appeal, however, the court of appeals held that Garrett had failed to meet this burden of proof and that the trial judge therefore should have withdrawn the case from the jury. The Pennsylvania Supreme Court affirmed the court of appeals’ judgment, holding that state law controlled the required burden of proof as a procedural rule. The case then came before the United States Supreme Court.