Legal Definitions - maritime-connection doctrine

The maritime-connection doctrine, also known as the locality-plus test, is a two-part legal standard used by courts to determine whether a case falls under admiralty jurisdiction. Admiralty jurisdiction allows federal courts to hear cases related to maritime law. For a case to satisfy this doctrine, it must meet both of the following criteria:

• Locality Test: The incident must have occurred on navigable waters, or the injury must have been caused by a vessel on navigable waters. Navigable waters are those used or capable of being used for commercial navigation.
• Connection Test: The incident must have a significant relationship to traditional maritime activity. This part of the test further examines two aspects:
  • Whether the incident has the potential to disrupt maritime commerce.
  • Whether the general character of the activity giving rise to the incident is substantially related to traditional maritime activity (e.g., navigation, shipping, cargo transport, maintenance of vessels).

If both parts of this test are met, a court can exercise admiralty jurisdiction over the case.

Examples:

• Collision in a Shipping Lane: A large container ship collides with a fishing trawler in a designated shipping lane leading to a major port, causing significant damage to both vessels and blocking the channel temporarily.

  • How it illustrates the doctrine: The Locality Test is met because the collision occurred on navigable waters (a shipping lane). The Connection Test is also satisfied because the incident involved two vessels engaged in maritime activities (commercial shipping and fishing), and the collision had the potential to disrupt maritime commerce by obstructing the channel and delaying other ships.

• Dockside Crane Malfunction: A longshoreman is injured on a pier when a crane, which is permanently affixed to a cargo ship, malfunctions while lifting a container from the vessel to the dock.

  • How it illustrates the doctrine: Even though the injury occurred on the dock, the Locality Test is met because the injury was caused by equipment (the crane) that is an appurtenance of a vessel on navigable waters. The Connection Test is met because the activity of unloading cargo from a ship is a traditional maritime activity, and a crane malfunction could disrupt maritime commerce by halting cargo operations.

• Oil Spill During Refueling: An oil tanker accidentally spills several barrels of crude oil into a bay while undergoing refueling operations at a port terminal.

  • How it illustrates the doctrine: The Locality Test is met because the oil spill occurred in navigable waters (the bay). The Connection Test is satisfied because the incident involved a vessel (oil tanker) and its operations (refueling), which are traditional maritime activities. The oil spill has the potential to disrupt maritime commerce by closing parts of the bay to navigation, impacting fishing, and requiring extensive cleanup efforts.