American Dredging Co. v. Miller

In American Dredging Co. v. Miller (1994) 510 U.S. 443, an injured seaman brought an action in Louisiana state court under the federal Jones Act and general maritime law. The defendant moved to dismiss under the doctrine of forum non conveniens, and the trial court granted the motion despite a Louisiana law that does not recognize the doctrine in Jones Act cases. The state Supreme Court reversed, concluding the state rule controls. The United States Supreme Court affirmed. The federal high court explained that the doctrine of forum non conveniens is "nothing more or less than a supervening venue provision," which is procedural rather than substantive. ( Id. at p. 453 127 L. Ed. at p. 297.) As such, choice-of-law principles require application of the state rule. (Ibid.)