Master Supreme Court held that a state workers’ compensation law could not be applied to a maritime injury occurring on navigable waters because it would disrupt the uniformity of federal maritime law. with this comprehensive case brief.
Southern Pacific Co. v. Jensen is a foundational decision at the intersection of constitutional structure and maritime law. It squarely addresses the tension between state police power—here, the application of a workers’ compensation statute—and the Constitution’s assignment of admiralty and maritime matters to the federal system. By invalidating the application of New York’s Workmen’s Compensation Law to a fatal longshoreman injury sustained over navigable waters, the Court announced a powerful uniformity principle: state law cannot materially alter or disturb the characteristic features of general maritime law.
Jensen’s legacy is twofold. First, it crystallized a preemption-like doctrine in admiralty, limiting state authority in maritime affairs in order to preserve national uniformity. Second, the decision catalyzed federal legislative action, ultimately leading to the Longshore and Harbor Workers’ Compensation Act (LHWCA) to fill the remedial gap Jensen exposed. For law students, the case is a staple in understanding federalism, the scope of Article III’s admiralty grant, the “saving-to-suitors” clause, and the continuing dialogue between the Court and Congress over maritime remedies.
244 U.S. 205 (1917), Supreme Court of the United States
Jensen was a longshoreman engaged in unloading cargo from a vessel owned by Southern Pacific Company that lay afloat in New York Harbor alongside a New York pier. While performing this maritime work aboard the vessel and thus over navigable waters, Jensen suffered fatal injuries. His widow sought compensation under New York’s Workmen’s Compensation Law, which imposed liability without fault and provided an administrative compensation remedy in lieu of traditional tort actions. The New York Industrial Commission awarded compensation against Southern Pacific, and the state courts sustained the award. Southern Pacific petitioned to the U.S. Supreme Court, arguing that application of the New York statute to a maritime injury occurring on navigable waters intruded on federal admiralty jurisdiction and undermined the uniformity of maritime law.
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.
The Court began with the Constitution’s extension of federal judicial power to all cases of admiralty and maritime jurisdiction (Article III), emphasizing the federal interest in uniform maritime rules for national and international commerce. Until Congress legislates otherwise, the general maritime law, as applied in federal courts, supplies the controlling substantive standards. While state law can incidentally affect maritime matters, it may not alter the substance of maritime rights and liabilities in ways that disturb uniformity. Applying the New York workers’ compensation scheme would fundamentally change the maritime regime: it imposes liability without fault, substitutes an administrative schedule of benefits for maritime remedies, and eliminates or reshapes maritime defenses and damages. If such state schemes were allowed to govern injuries over navigable waters, maritime law would fragment into a patchwork of varying state rules, precisely what the uniformity principle forbids. The Court rejected the argument that the saving-to-suitors clause permitted the state award. That clause preserves the ability to pursue common-law remedies in appropriate forums; it does not authorize states to create new substantive liabilities that supplant maritime law. Nor did the “local concern” characterization suffice; the situs and nature of the work were maritime, and the incident occurred over navigable waters where admiralty law traditionally controls. The Court acknowledged that Congress could legislate to provide compensation but held that, absent such federal action, states could not reshape maritime rights. In dissent, Justice Holmes argued that the State should be free to provide a remedy, but the majority maintained that the Constitution demands federal supremacy and uniformity in maritime matters.
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.
The saving-to-suitors clause in the Judiciary Act preserves to suitors “all other remedies to which they are otherwise entitled,” allowing certain maritime claims to be pursued in state courts using common-law procedures. Jensen held that this clause preserves remedies (procedural avenues) but does not authorize states to create or apply substantive rules that alter maritime rights and liabilities. In other words, states may provide a forum and certain procedural mechanisms, but they cannot impose a different substantive compensation regime for over-water maritime injuries.
No. States may regulate and supply rules that do not materially prejudice characteristic features of maritime law or disrupt its uniformity. For example, states may apply generally applicable laws that do not conflict with maritime rules or may provide remedies where maritime law is silent and uniformity is not threatened. But for injuries occurring over navigable waters in the course of maritime work, states generally cannot substitute their own compensation or liability standards for those of maritime law.
After early attempts to authorize state compensation schemes for maritime injuries were struck down on uniformity grounds, Congress enacted the Longshore and Harbor Workers’ Compensation Act (1927). The LHWCA created a federal, uniform compensation system for non-seaman maritime workers injured over navigable waters (and, after amendments, certain adjoining areas). This legislation filled the gap Jensen exposed while preserving national uniformity.
Yes, in its core principle. The notion that state law cannot materially interfere with the uniformity of maritime law remains. However, much of the practical space where Jensen once blocked state compensation is now occupied by federal statutes like the LHWCA and by subsequent doctrine recognizing limited areas for state regulation that do not disrupt uniformity. Additionally, later cases allow concurrent state workers’ compensation for certain land-based injuries even when the LHWCA applies, so long as uniformity over navigable waters is not compromised.
Start with situs (did the injury occur over navigable waters?) and status/nature of the work (is it maritime in character?). Identify the state law being applied and ask whether it changes substantive maritime rights or remedies. Apply the Jensen test: would the state rule materially prejudice characteristic features of maritime law or interfere with its harmony and uniformity? Consider the saving-to-suitors clause (remedies vs. substantive rights), and check whether Congress has enacted a governing federal statute (e.g., LHWCA, Jones Act). Conclude with whether state law may supplement or is precluded.
Justice Holmes’s dissent contended that uniformity should not preclude states from providing practical remedies for local injuries and read the saving-to-suitors clause more broadly to permit state-created rights. The dissents are important because they highlight the policy tension between effective local remedies and strict national uniformity—a debate that later influenced Congress to craft a federal compensation scheme and continues to inform modern preemption and admiralty analyses.
Southern Pacific Co. v. Jensen stands as a landmark declaration that maritime law must remain uniform and that states may not supplant it with their own substantive regimes for injuries over navigable waters. By invalidating the application of a state workers’ compensation statute to a maritime injury, the Court reinforced federal supremacy in the admiralty sphere and set a durable doctrinal boundary for state regulation.
At the same time, Jensen’s rigidity revealed a remedial gap that Congress ultimately filled through comprehensive federal legislation. The case thus exemplifies the dynamic interplay between judicial enforcement of constitutional structure and legislative responses to ensure practical justice—an enduring lesson in federalism and the separation of powers within the maritime context.