Nature of the Case
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Facts
P was injured while working as a seaman for D on a vessel traveling between the United States and European ports, and spent a number of months in hospitals in Poland, and the United States. P brought suit in a Pennsylvania state court for damages pursuant to §33 of the Merchant Marine (Jones) Act. P claimed his condition to a blow by a hatch cover which allegedly fell on him through D's negligence. D claimed that if serious injuries did exist they were caused by a fight in Copenhagen or by accidents prior to the voyage. D also alleged that for a consideration of $100 P had executed a full release. P denied having signed such an instrument, and claimed that his signature was obtained through fraud and misrepresentation, and without 'legal, binding and valid consideration.' P did execute a release for $100 several days after his return to this country. His testimony was that he was under the influence of drugs taken to allay the pain of his injury, that he was threatened with imprisonment if he did not sign as directed, and that he considered the $100 a payment of wages. The jury rendered a verdict for P for $3000 under the Jones Act, and $1000 for maintenance and cure. The court gave judgment to D non obstante veredicto because P had failed to sustain the burden of proof required under Pennsylvania law to invalidate the release. The court conceded that 'in admiralty cases, the responsibility is on D to sustain a release rather than on P to overcome it,' but concluded that since P had chosen to bring his action in a state, rather than in an admiralty, court, his case must be governed by local, rather than admiralty law. In Pennsylvania, one who attacks the validity of a written release has the burden of sustaining his allegation by 'clear, precise, and indubitable' evidence, meaning evidence 'that is not only found to be credible but of such weight and directness as to make out the facts alleged beyond a reasonable doubt.' The Supreme Court of Pennsylvania held that in an action of this sort, the Pennsylvania court was obligated 'to apply the federal law creating the right of action in the same sense in which it would have been applied in the federal courts.' It affirmed the judgment in the belief that the rule as to burden of proof on releases does not affect the substantive rights of the parties, but is merely procedural, and is therefore controlled by state law. P appealed.
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