Lewis v. Lewis & Clark Marine

In 1998, James F. Lewis, a deckhand aboard the M/V Karen Michelle owned by Lewis & Clark Marine, Inc., claimed that he was injured when he tripped over a wire on the boat. Lewis then sued Lewis & Clark in Illinois County Court, for personal injuries claiming negligence under the Jones Act. Lewis & Clark had already filed a complaint for exoneration from, or limitation of, liability in the District Court under the Limitation of Liability Act (Act). Subsequently, the court approved a surety bond of $450,000, representing Lewis & Clark's interest in the vessel, ordered that any claim related to the incident be filed with the court within a specified period, and enjoined the filing or prosecution of any suits related to the incident. The injunction prevented Lewis from litigating his personal injury claims in state court and he moved to dissolve it. The District Court noted that federal courts have the exclusive jurisdiction to determine whether a vessel owner is entitled to limited liability, but also recognized that the statute conferring exclusive jurisdiction over admiralty and maritime suits to federal courts saves to suitors "all other remedies to which they are other wise entitled." Ultimately, the court dissolved the injunction. The Court of Appeals reversed.