Gammon v. City of New York, 85 N.Y.2d 791 (1995)
Federal maritime law does not automatically preempt state law; state laws may apply in maritime cases when the matter is “maritime but local” and the state regulation does not unduly interfere with federal maritime interests or the uniformity of maritime law.
Summary
Willie Gammon, a dock builder, was injured while repairing a pier in New York City. He sued the city and the general contractor under New York Labor Law, which imposes strict liability in certain construction accidents. The defendants argued that federal maritime law preempted the state law claims. The New York Court of Appeals held that the state labor laws were not preempted because the matter was “maritime but local,” and applying state law would not disrupt federal maritime uniformity or interests, especially given the state’s strong interest in worker safety.
Facts
Willie Gammon, a foreman dock builder, was injured while repairing a wood fender system at the South Bronx Marine Transfer Station, owned and operated by New York City. Anjac Enterprises, Inc. was contracted to repair the structures, and they subcontracted the pier repair to Macro Enterprises, Ltd., Gammon’s employer. Gammon worked from a float stage in navigable waters, secured to the land-based transfer station. He was cutting timber when a passing tugboat caused turbulence, dislodging a heavy timber that struck him. He received compensation under the Longshore and Harbor Workers’ Compensation Act (LHWCA).
Procedural History
Gammon sued the City and Anjac in Supreme Court, alleging violations of New York Labor Law. Anjac filed a third-party complaint against Macro. The City and Anjac moved for summary judgment, arguing federal maritime law preempted the state law claims. Gammon cross-moved for partial summary judgment. The Supreme Court granted the defendants’ motion, dismissing the complaint. The Appellate Division reversed and reinstated the complaint, holding that the Labor Law claims were not preempted. The Court of Appeals granted leave to appeal.
Issue(s)
Whether Federal maritime law preempts New York Labor Law §§ 200, 240(1), and 241(6) in a case where a dock builder is injured on a floating platform attached to a land-based pier undergoing repairs.
Holding
Yes, the Appellate Division’s order was properly made because under the circumstances presented, plaintiff’s Labor Law claims are not preempted by Federal maritime law.
Court’s Reasoning
The Court acknowledged admiralty jurisdiction but emphasized that it does not automatically displace state law. The court analyzed whether the state rule conflicted with federal law, hindered uniformity, made substantive changes, or interfered with maritime law. It cited the “maritime but local” doctrine, which allows state law to apply when it addresses local matters and does not materially prejudice general maritime law or its uniformity. The Court noted that protecting workers engaged in maritime activities is an objective of federal maritime law. Applying state strict liability in this case, where the tort was maritime but local and involved a land-based repair, would not unduly interfere with the federal interest in maintaining the free flow of maritime commerce. The court emphasized New York’s strong interest in protecting worker safety and that strict liability is not entirely foreign to maritime law, citing examples such as the doctrine of seaworthiness and LHWCA. The court concluded that applying New York Labor Law would not unduly interfere with maritime commerce or fundamental maritime law principles, and therefore, preemption was not warranted in this case. The court underscored the Labor Law’s strong State interest in protecting workers and that because strict liability is not wholly at odds with Federal maritime principles, there was no reason for the Labor Law’s provisions to be displaced in the context of this local land-based repair. The court limited its holding to the preemption issue, leaving other issues regarding the validity of the Labor Law claims open.