The question
Whether choice-of-law provisions in maritime insurance contracts are presumptively enforceable under federal maritime law.
Great Lakes Ins. SE v. Raiders Retreat Realty Co.
What the Court decided
The Court reversed the Third Circuit and held that choice-of-law provisions in maritime contracts are presumptively enforceable under federal maritime law, subject to narrow exceptions that did not apply here. Federal maritime law seeks a uniform system, and longstanding precedent treating forum-selection clauses as presumptively valid dictates the same rule for choice-of-law clauses. Wilburn Boat did not require a different result because it addressed state law only as a gap-filler where no uniform federal rule existed, and here a uniform federal rule governs. The parties' selection of New York law was therefore enforceable.
How the justices split
UnanimousThe Court's opinion
Kavanaugh, joined by Roberts, Thomas, Alito, Sotomayor, Kagan, Gorsuch, Barrett, Jackson
Federal maritime law requires a uniform system, and choice-of-law provisions in maritime contracts are presumptively enforceable subject to narrow exceptions. The Court reasoned that its precedent treating forum-selection clauses as prima facie valid dictates the same rule for choice-of-law clauses, which similarly reduce confusion and litigation costs. Wilburn Boat did not control because it applied state law only as a gap-filler where no uniform federal rule existed, and here a uniform federal rule governs enforceability, so no gap remains for state law to fill.
Concurring
Thomas, writing alone
Thomas filed a concurring opinion. The syllabus records the concurrence at page 79 but does not state its reasoning.
How we know · 5 sourced claims
The Court held that choice-of-law provisions in maritime contracts are presumptively enforceable under federal maritime law, with narrow exceptions not applicable here.
Source: syllabus, Held
Kavanaugh delivered the opinion for a unanimous Court, and Thomas filed a concurring opinion.
Source: syllabus, lineup
The Court relied on its forum-selection-clause precedent, under which such clauses are prima facie valid, to reach the same conclusion for choice-of-law provisions.
Source: syllabus, Held
Wilburn Boat did not require a different result because it applied state law only as a gap-filler where no uniform federal maritime rule existed.
Source: syllabus, Held
The case arose from a marine insurance contract selecting New York law after Raiders' boat ran aground in Florida, reviewed on certiorari to the Third Circuit.
Source: syllabus, Held