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Great Lakes Insurance SE v. Raiders Retreat Realty Co.
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Docket:
22-500
Opinion Date: February 21, 2024
Judge:
Kavanaugh
Areas of Law:
Admiralty & Maritime Law, Contracts, Insurance Law
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In a maritime insurance dispute between Great Lakes Insurance, a German company, and Raiders Retreat Realty, a Pennsylvania company, the Supreme Court of the United States ruled that choice-of-law provisions in maritime contracts are presumptively enforceable under federal maritime law, with certain narrow exceptions not applicable in this case.
The dispute originated when Raiders Retreat Realty's boat ran aground, and Great Lakes Insurance denied coverage, alleging that Raiders breached the insurance contract by failing to maintain the boat’s fire-suppression system. The insurance contract contained a choice-of-law provision that selected New York law to govern future disputes. Raiders argued that Pennsylvania law, not New York law, should apply. The District Court ruled in favor of Great Lakes, finding that the choice-of-law provision was presumptively valid and enforceable under federal maritime law. The Third Circuit Court of Appeals vacated this decision, holding that choice-of-law provisions must yield to the strong public policy of the state where the suit is brought.
The Supreme Court reversed the Third Circuit's decision, emphasizing the importance of uniformity and predictability in maritime law. The Court concluded that choice-of-law provisions allow maritime actors to avoid later disputes and the ensuing litigation and costs, thus promoting maritime commerce. Therefore, such provisions are presumptively enforceable under federal maritime law. The Court further clarified that exceptions to this rule exist but are narrow, and none of them applied in this case.
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McElrath v. Georgia
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Docket:
22-721
Opinion Date: February 21, 2024
Judge:
Jackson
Areas of Law:
Constitutional Law, Criminal Law
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In 2012, Damian McElrath, a young man diagnosed with multiple serious mental health disorders, killed his mother. Georgia charged McElrath with three crimes: malice murder, felony murder, and aggravated assault. At trial, McElrath asserted an insanity defense. The jury found him not guilty by reason of insanity on the malice-murder charge but guilty but mentally ill on the felony-murder and aggravated-assault charges. The state courts, however, decided that these verdicts were "repugnant" because they required contradictory conclusions about McElrath's mental state at the time of the crime. They therefore nullified both the "not guilty" and "guilty" verdicts and authorized McElrath’s retrial.
The Supreme Court of the United States held that the Double Jeopardy Clause of the Fifth Amendment prevents the State from retrying McElrath for the crime that had resulted in the “not guilty by reason of insanity” finding. The court clarified that a jury’s determination that a defendant is not guilty by reason of insanity is a conclusion that “criminal culpability had not been established,” just as much as any other form of acquittal. Despite the seemingly inconsistent findings, the court emphasized that, once rendered, a jury’s verdict of acquittal is inviolate, and the Double Jeopardy Clause prohibits second-guessing the reason for a jury’s acquittal. The Supreme Court reversed the judgment of the Supreme Court of Georgia and remanded the case for further proceedings not inconsistent with its opinion.
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