The Exclusive Admiralty Jurisdiction

In Cline v. Price the owners of a minority interest in a fishing vessel, being dissatisfied with the use to which it was being put, brought suit in Superior Court against the majority owners. The action prayed the appointment of a receiver, an accounting, and a partition of the vessel by sale and distribution of the proceeds. A demurrer was sustained by the lower court and affirmed by the Supreme Court. The ground assigned was that the suit, essentially one for partition, was exclusively within the admiralty jurisdiction of the United States, and the state courts have no jurisdiction to afford such relief. This pitfall of exclusive admiralty jurisdiction is one which the practitioner in our maritime state of Washington may often have occasion to meet. It shall be the purpose of this article to discuss some of the fundamental aspects of the admiralty jurisdiction in general, with particular emphasis upon those classes of cases where the suitor is limited in his choice of forum to the federal courts sitting in admiralty