ADMIRALTY-MAINTENANCE AND CURE

The recent decision of Warren v. United States marks another instance of the growing interest of the Supreme Court in the remedies given injured seamen. The right of the seaman to maintenance and cure can be found in the earliest formulations of a law of the sea and is present in our admiralty law today. The ancient terminology is still used but the tendency is to construe the language liberally in favor of the seaman. This comment is intended as a short survey of the development of the remedy in this country as represented by the landmark cases.

It will not be concerned with the infinite variety of factual situations which may be found in the lower court decisions, but rather will deal only with the broad outline of the subject matter. Questions incidental to the remedy--e.g., who is a seaman, who is the owner, what will be considered to be a ship--will not be considered. Likewise, the obviously related problem of negligence in furnishing maintenance and cure does not fall within the scope of this comment.