Fisherman's wage dispute entitled to admiralty jurisdiction.
In Gruver v. Lesman Fisheries, the Ninth Circuit held that the admiralty court had jurisdiction over a case arising from personal injuries received in a physical confrontation arising from a dispute over wages for a commercial fisherman. The fight occurred on board a ship due to leave the next morning for a fishing expedition. The parties stipulated that the fight occurred on a ship floating on navigable waters, a location requirement for admiralty jurisdiction. The parties also agreed that the fight had the ability to disrupt maritime commerce. The disagreement arose over the “connection” requirement for jurisdiction.
The Court held the matter giving rise to the fight, the wage dispute, showed a substantial relationship to traditional maritime activity, as it involved a failure to pay wages for services performed aboard a commercial vessel. The Court rejected defendant’s claim that the fight, rather than the underlying cause of the fight, was the appropriate focus of this second part of the connection requirement.
