Donaldson v. National Marine, Inc.

Summary

The Supreme Court of California held that California state courts have concurrent subject matter jurisdiction over wrongful-death claims brought under the federal Jones Act, including claims arising from injuries occurring outside California's territorial waters. The court further held that the defendant had not established a jurisdictional or other valid basis for preventing California courts from exercising that concurrent jurisdiction and affirmed the judgment of the Court of Appeal.

Holdings

1. California state courts possess concurrent jurisdiction with federal courts over Jones Act claims, including wrongful-death claims arising from maritime employment outside California territorial waters.
2. The absence of California-resident parties or California-based conduct did not deprive California courts of subject matter jurisdiction over the Jones Act claim.
3. Any argument that California was an inconvenient forum concerned venue or forum non conveniens rather than subject matter jurisdiction, and defendant waived that argument by failing to assert it at trial.

Questions Presented

1. Whether California state courts have concurrent subject matter jurisdiction over wrongful-death claims brought under the federal Jones Act when the maritime injury or death occurred outside California territorial waters.
2. Whether the absence of California-resident parties or California-based tortious conduct deprived California courts of subject matter jurisdiction over the Jones Act claim.
3. Whether defendant's insufficient-contacts argument concerned personal jurisdiction or venue rather than subject matter jurisdiction, and whether those objections were waived.

Disposition

affirmed