244 U.S. 205 (1917), Supreme Court of the United States
Southern Pacific Co. v.
May a state apply its workers' compensation statute to a maritime injury sustained by a longshoreman while working aboard a vessel on navigable waters, or does the Constitution's allocation of admiralty and maritime jurisdiction and the need for uniform maritime law preclude such application?
State law may supplement maritime law only to the extent it does not work material prejudice to the characteristic features of the general maritime law or interfere with its proper harmony and uniformity in international and interstate relations. The Judiciary Act's saving-to-suitors clause preserves common-law remedies but does not authorize states to create or apply substantive rules that alter or displace controlling maritime law. Congress may modify maritime law, but absent federal legislation, the general maritime law governs uniformly.
No. New York's Workmen's Compensation Law cannot constitutionally be applied to an injury sustained by a longshoreman while performing maritime work over navigable waters. The state award was set aside because the statute, as applied, would materially prejudice the characteristic features of maritime law and destroy its needed uniformity.
Jensen is the cornerstone of the maritime uniformity doctrine. It limits state authority in maritime cases by holding that state laws cannot alter substantive maritime rights and liabilities for injuries occurring on navigable waters. The decision ushered in the so-called "Jensen line," demarcating when state law is precluded in admiralty. Although later cases recognized a narrow "maritime but local" allowance for non-disruptive state regulation and remedies, Jensen's core uniformity principle endures. Congress ultimately addressed the remedial gap by enacting the Longshore and Harbor Workers' Compensation Act (1927), creating a federal compensation scheme for non-seaman maritime workers. For federalism and federal courts courses, Jensen illustrates how constitutional structure and the need for national uniform rules can displace state police power, while also demonstrating how judicial decisions can prompt legislative solutions.