Lewis v. Lewis & Clark Marine, Inc.

531 U.S. 438, 121 S.Ct. 993, 148 L.Ed.2d 931, 2001 AMC 913 (2001)

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Lewis v. Lewis & Clark Marine, Inc.

United States Supreme Court
531 U.S. 438, 121 S.Ct. 993, 148 L.Ed.2d 931, 2001 AMC 913 (2001)

CS

Facts

James F. Lewis (James) (plaintiff) was injured while working on the M/V Karen Michelle, a vessel owned by Lewis & Clark Marine, Inc. (Lewis & Clark) (defendant). James sued Lewis & Clark in state court for negligence under the Jones Act, unseaworthiness, and maintenance and cure. Lewis & Clark brough a liability-limitation action in federal district court. The federal district court initially issued an injunction against any other suits against Lewis & Clark arising from the incident that injured James. The district court dissolved the injunction, however, after James responded that he was the sole claimant under those events, that he waived any claim of res judicata concerning limited liability, and that his claim amounted to less that the value of the limitation amount. The district court therefore allowed James to proceed with his state-court claim but stayed the limitation action in the event that further proceedings were needed. The court of appeals, however, determined that the district court erred in dissolving the injunction and allowing James’s state claim to proceed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (O’Connor, J.)

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