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Keywords

contracttortplaintiffjurisdictionnegligencestatuteappealmotion

tortplaintiffjurisdictionliabilityappealcitizenshiphigh seas

Related Cases

In re Oil Spill by Amoco Cadiz off Coast of France on March 16, 1978, 699 F.2d 909, 19 ERC 1596, 1983 A.M.C. 1633, 37 Fed.R.Serv.2d 589

Facts

The supertanker Amoco Cadiz, built by Astilleros Espanoles, S.A., broke up off the coast of France in 1978, resulting in a significant oil spill that caused damage to French citizens. The plaintiffs filed a suit in federal district court in Chicago, alleging negligence against the shipowner and the shipbuilder. The shipbuilder attempted to dismiss the case, claiming lack of jurisdiction, but the district court denied the motion and entered a default judgment against the shipbuilder after it failed to respond.

The supertanker Amoco Cadiz, which had been built in Spain by a Spanish company, Astilleros Espanoles, S.A., broke up off the coast of France in 1978, causing an extensive oil spill.

Issue

Did the district court have personal jurisdiction over the shipbuilder, and were the claims against it within admiralty jurisdiction?

Although the only ground Astilleros raises on appeal is personal jurisdiction, we shall consider on our own initiative whether a products liability claim against a shipbuilder, arising out of a shipwreck on the high seas, is within the federal admiralty jurisdiction.

Rule

The court applied the principles of admiralty jurisdiction, which allows federal courts to hear cases involving maritime torts, and the Illinois long-arm statute, which permits jurisdiction over nonresidents who transact business in the state.

The admiralty jurisdiction gives the federal courts jurisdiction, to a significant extent exclusive, see Currie, Federal Jurisdiction 122 (1981), over a class of disputes that need not involve a federal question or diversity of citizenship.

Analysis

The court found that the allegations in the complaint and cross-claim established that the shipbuilder was a culpable party in a maritime tort, thus bringing the claims within admiralty jurisdiction. Additionally, the negotiation and signing of the shipbuilding contract in Illinois constituted sufficient business transactions to satisfy the Illinois long-arm statute, allowing for personal jurisdiction over the shipbuilder.

The allegations in the complaint and cross-claim that Astilleros is a culpable party in a maritime tort bring both claims within the admiralty jurisdiction directly; they need not be tied to the French plaintiffs' claim against Amoco.

Conclusion

The Court of Appeals affirmed the district court's judgment, concluding that both the complaint and cross-claim against the shipbuilder were properly within the court's jurisdiction.

The district court had jurisdiction over both the complaint and cross-claim against Astilleros, the default judgments are Affirmed.

Who won?

The French citizens prevailed in the case as the court upheld the default judgment against the shipbuilder, affirming that jurisdiction was properly established.

The French plaintiffs' action against Amoco, at least, is within the admiralty jurisdiction; any doubt on that score created by the fact that the damage occurred on land… is removed by the Admiralty Jurisdiction Extension Act, 46 U.S.C. § 740.

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