Atlantic and Gulf Stevedores, Inc. v. Ellerman Lines, Ltd

In Atlantic and Gulf Stevedores, Inc. v. Ellerman Lines, Ltd., 369 U.S. 355, 82 S.Ct. 780, 7 L.Ed.2d 798 (1962), a longshoreman injured while unloading cargo brought suit against the owners of the ship carrying the cargo. Diversity jurisdiction existed, and the plaintiff designated the action as one at law and demanded a jury trial. The vessel owners impleaded the stevedore for whom the longshoreman worked, arguing that the stevedore was negligent as to the manner in which the vessel was unloaded and that the stevedore should indemnify the vessel owners if they were found liable to the longshoreman. Answering special interrogatories, the jury found the vessel owners liable but found no fault on the part of the stevedore. On appeal, the circuit court affirmed the jury's verdict against the vessel owners but reversed the judgment in favor of the stevedore, concluding that the stevedore was negligent as a matter of law. See id. at 357-58, 82 S.Ct. 780. The Supreme Court reversed the decision of the circuit court. The Court explained that "the requirements of the Seventh Amendment were brought into play in this case, even though a stevedoring contract is a maritime contract." Id. at 359, 82 S.Ct. 780. The Court held that "this suit being in the federal courts by reason of diversity of citizenship carried with it, of course, the right to trial by jury," id. at 360, 82 S.Ct. 780, and that the manner in which the circuit court rejected the jury verdict violated the Seventh Amendment's prohibition against the re-examination of facts found by a jury. See id. at 364, 82 S.Ct. 780.