American Dredging Co. v. Miller

Summary

The Court, in an opinion by Justice Scalia joined by Chief Justice Rehnquist and Justices Blackmun, O'Connor, Souter, and Ginsburg, affirmed Louisiana's judgment that federal maritime law does not require state courts to apply federal forum non conveniens doctrine in maritime and Jones Act actions involving domestic parties. The doctrine is procedural, is not a characteristic feature peculiar to admiralty, and does not require uniform application. Justice Stevens also joined Part II-C, which relied on the Jones Act and related federal legislation. Justice Souter separately emphasized that difficult substance-procedure classifications should turn on interference with the free flow of maritime commerce. Justice Stevens concurred in part and in the judgment, agreeing with the procedural and statutory grounds but urging abandonment of Jensen's special maritime preemption framework. Justice Kennedy, joined by Justice Thomas, dissented, arguing that forum non conveniens is an essential maritime protection promoting uniformity, comity, and commerce and that state courts must consider the defense.