Aston Bartholomew v. Universe Tankships, Inc.

263 F.2d 437, 1 Fed. R. Serv. 2d 621, 1959 U.S. App. LEXIS 5140
CourtCourt of Appeals for the Second Circuit
DecidedJanuary 9, 1959
Docket22, Docket 25011
StatusPublished
Cited by142 cases

This text of 263 F.2d 437 (Aston Bartholomew v. Universe Tankships, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aston Bartholomew v. Universe Tankships, Inc., 263 F.2d 437, 1 Fed. R. Serv. 2d 621, 1959 U.S. App. LEXIS 5140 (2d Cir. 1959).

Opinions

MEDINA, Circuit Judge.

Aston Bartholomew, a citizen of the-British West Indies, was a seaman on board the Ulysses, a vessel owned and' operated by appellant, a Liberian corporation, and flying the flag of Liberia. On April 15, 1952, as the vessel was proceeding within the three-mile limit, and' hence in the territorial waters of the United States, Bartholomew was assaulted by a fellow member of the crew who-had previously attacked other seamen. The complaint alleged a claim based upon the Jones Act, another based upon alleged unseaworthiness under the Maritime Law and a third claim for maintenance and cure, also under the Maritime-Law. Over the objection of appellant. [439]*439the trial judge held: that the circumstances disclosed by the evidence made the Jones Act applicable; that, although the trial was had on the civil side of the Court to a judge and jury, and not in admiralty, there was pendent jurisdiction over the maritime cause for unseaworthiness of the vessel; and he submitted both the Jones Act claim and the maritime cause for unseaworthiness to the jury, reserving the maintenance and cure maritime cause for decision by himself as a “judge in admiralty,” his determination to be based upon the evidence adduced at the trial and such further proofs as the parties might wish to offer later. The jury found for Bartholomew on each of the claims submitted to it, fixing the damages in the sum of $24,-600, or $25,000, less the $400 paid upon the signing of a release by Bartholomew which the jury disregarded as not binding on him. The maintenance and cure claim is held in abeyance pending the outcome of this appeal.

Appellant contends: that the court below improperly found the Jones Act applicable ; that in any event the maritime cause should not have been submitted to the jury; that it was error to refuse to give certain instructions to the jury as requested by appellant; and that the motion to set aside the verdict and grant a new trial should have been granted because the jurors allegedly compromised their views on the subject of damages. We shall discuss seriatim these points and the evidence and the portions of the record relevant to each.

Applicability of the Jones Act

Did the District Court err in holding that Bartholomew had a right to invoke the Jones Act against his employer, a Liberian corporation? In Lauritzen v. Larsen, 1953, 345 U.S. 571, at page 582, 73 S.Ct. 921, at page 928, 97 L.Ed. 1254, the Supreme Court tells us that the answer is to be found by “ascertaining and valuing points of contact between the transaction and the states or governments whose competing laws are involved,” and by “weighing * * * the significance of one or more connecting factors between the shipping transaction regulated and the national interest served by the assertion of authority,” such as the place of the wrongful act, the law of the flag, the allegiance or domicile of the claimant, the allegiance of the shipowner, the place of contract between the parties, the inaccessibility of the foreign forum and the law of the forum.

A study of the numerous adjudicated Jones Act cases reveals not only the vagueness inherent in the general and undefined direction in Lauritzen for the “valuing” and “weighing” of the various facts or groups of facts that are said to be “points of contact” between the transaction and the states whose competing laws are involved, but also a lack of any common principle of decision or method of approach to the problem. Sometimes the courts seem to be employing choice of law techniques, and not infrequently the result arrived at seems to be based on mere dialectic manipulation or guesswork. All this, however, is to be expected as new law develops in a new field. This substantial background of judicial consideration of a great variety of combinations of relevant factors in cases where application of the Jones Act is asserted on the one hand and denied on the other makes it possible for us to undertake a restatement of the method of approach and the principles to be applied.

To begin with, as pointed out in Lau-ritzen, 345 U.S. at page 578, 73 S.Ct. at page 926, “we are simply dealing with a problem of statutory construction.” For this reason traditional choice of law techniques may be more misleading than helpful.

In the second place, certain possible interpretations of the Jones Act have already been rejected, and their elimination simplifies the problem. For example, when the question was first presented it might have been held that in the enactment of the Jones Act the Congress intended to exercise the full measure of its power over the subject of the legis* lation, in which event any contact between the transaction and the United States would have been sufficient to war[440]*440rant its application. But a contrary view prevailed. See The Paula, 2 Cir., 1937, 91 F.2d 1001, certiorari denied sub nom., Peters v. Lauritzen, 302 U.S. 750, 58 S.Ct. 270, 82 L.Ed. 580; O’Neill v. Cunard White Star, 2 Cir., 1947, 160 F.2d 446, certiorari denied 332 U.S. 773, 68 S.Ct. 56, 92 L.Ed. 358. Such inclusiveness was not read into the statute, since it was assumed that the Congress intended the Jones Act to be given a construction in consonance with international maritime law. This meant that not every contact, no matter how ephemeral or fortuitous it might be, would be deemed a basis for applying American law, that is to say the Jones Act. Instead, as commented on in Lauritzen (345 U.S. at page 582, 73 S.Ct. at page 928) “the necessity of mutual forbearance” to avoid international retaliation, and the desire to avoid changing and variant regulations aboard ship, have been stressed. Moreover, the courts might have so construed the Jones Act as to make some particular factor indispensable; but they did not. In other words, even if it appeared that a single special factor of obvious significance was lacking the Jones Act has been held to be applicable despite the absence of such a factor.

Thus the Jones Act has often been applied although the “flag of the ship” was foreign. E.g., Uravic v. F. Jarka Co., 1931, 282 U.S. 234, 51 S.Ct. 111, 75 L.Ed. 312; Gerradin v. United Fruit Co., 2 Cir., 1932, 60 F.2d 927, certiorari denied 287 U.S. 642, 53 S.Ct. 92, 77 L.Ed. 556; Gambera v. Bergoty, 2 Cir., 1942, 132 F.2d 414, certiorari denied 1943, 319 U.S. 742, 63 S.Ct. 1030, 87 L.Ed. 1699. Ownership of the vessel by American citizens was also lacking in the Uravic and Gambera cases.

That the tort need not occur in domestic waters was clearly shown in Panama R. Co. v. Johnson, 1923, 264 U.S. 375, 44 S.Ct. 391, 68 L.Ed. 748; Carroll v. United States, 2 Cir., 1943, 133 F.2d 690; Wenzler v. Robin Line S.S. Co., D.C.W.D. Wash.1921, 277 F. 812. In the Carroll case, supra, and in Torgersen v. Hutton, 2nd Dept. 1934, 243 App.Div. 31, 276 N.Y.S. 348, affirmed 1935, 267 N.Y. 535, 196 N.E. 566, certiorari denied, 1935, 296 U.S. 602, 56 S.Ct. 118, 80 L.Ed. 426, the seaman was neither a citizen nor domiciliary of the United States.

Other contacts such as the place of contract and the origin and destination of the vessel have probably never even been suggested as indispensable.

Nor can a “center of gravity” or “place of most vital connection” approach properly rationalize the decided cases.

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Bluebook (online)
263 F.2d 437, 1 Fed. R. Serv. 2d 621, 1959 U.S. App. LEXIS 5140, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aston-bartholomew-v-universe-tankships-inc-ca2-1959.