American Dredging Company v. Miller (1993)
- Docket
- 91-1950
- Decided
- 1993-01-01
Summary
Question: Does the Constitutional grant of federal jurisdiction over maritime law (found in Article III Section 2) prevent states from prohibiting (in maritime cases) "forum non conveniens" claims that, under federal law, would be permitted? Conclusion: No. The Court decided that "forum non conveniens" claims were only procedural, not substantive, and that national uniformity was therefore not required by the Constitution. Writing for the seven-member majority, Justice Antonin Scalia stated "venue is a matter that goes to process rather than substantive rights -- determining which among various competent courts will decide the case. Uniformity of process (beyond the rudimentary elements of procedural fairness) is assuredly not what the law of admiralty seeks to achieve, since it is supposed to apply in all the courts of the world." Further, Scalia wrote that the amount of discretion left to the trial court by the forum non conveniens doctrine necessarily meant that, even if it was embraced by every state, it would still not result in uniformity.