EXERCISE OF ADMIRALTY JURISDICTION DOES NOT MEAN STATE LAW IS AUTOMATICALLY PREEMPTED.
Willie Cammon, Respondent, v. City of New York et al.,Appellants. Anjac Enterprises, Inc., Third-Party Plaintiff, v. MacroEnterprises, Inc., Third-Party Appellant. William M. Kimball, for third-partyappellant.
No. 126
COURT OF APPEALS OF NEW YORK
2000 N.Y. LEXIS 3902
December 21, 2000, Decided
OVERVIEW: Plaintiff injured employee sued defendant general contractor and city, and alleged violations of state labor laws after he was injured while doing repair work on a floating raft on navigable waters, but where the raft was anchored to land and the repair work involved a land structure. Defendant general contractor and city moved for summary judgment on the ground that federal maritime law preempted state labor law. The trial court granted the motion. The appellate court reversed and held plaintiff's causes of action were not preempted by federal maritime law. Leave to appeal was granted. The court affirmed the order reversing the grant of summary judgment and concluded the appellate court properly ruled that the causes of action were not preempted. Exercise of admiralty jurisdiction did not automatically mean state law was preempted and in the present case the "maritime but local rule" applied because even though plaintiff was on a floating raft in navigable waters, the raft was anchored to land and the repair was to a land structure. As a result, exercise of state law would not frustrate federal maritime law.
OUTCOME: Order reversing the grant of summary judgment to defendant general contractor and city affirmed and certified question about whether the appellate division acted properly in granting the reversal answered in the affirmative because plaintiff's complaint alleging violations of state labor law was not preempted by federal maritime law as the state's strict liability statutes were not at odds with federal maritime law in the present case.
