Vanderbilt Journal of Transnational Law


Journal Staff

First Page



Plaintiff, a Greek seaman, sought relief in federal court under the Jones Act for injuries suffered aboard ship while docked in a United States seaport. Defendants, corporations, controlled by a permanent resident alien of the United States, contended the Court was without jurisdiction since they were not employers within the meaning of the Jones Act and because the contract of employment with plaintiff provided for the application of Greek law. The District Court found for the plaintiff. The Fifth Circuit affirmed.

On certiorari to the United States Supreme Court, held, affirmed. A shipowner with substantial business contacts in the United States who receives the benefits of American citizenship is an "employer" within the meaning of the Jones Act. Hellenic Lines Ltd. v. Roditis, 398 U.S. 306 (1970). Admiralty law has traditionally allowed recovery by a seaman from his employer for care and maintenance expenses under an implied warranty of a seaworthy vessel. The Jones Act of 1920 provided a new remedy for seamen: recovery for negligence of the shipowner or fellow servants. Although there was no discussion of this particular provision in the Congressional debates, the Legislature apparently intended to protect foreign as well as domestic seamen.