Note:
Billy Coe Dyer, The Jury on the Quarterdeck: The Effect of Pleading Admiralty Jurisdiction When a Proceeding Turns Hybrid, 63 Texas L. Rev. 533 (1984).
 

Abstract:
In “The Jury on the Quarterdeck,” Dyer analyzes and critiques the tension between the traditions of admiralty jurisdiction and the constitutional right to trial by jury. Dyer discusses some of the most common problems in hybrid cases – cases consisting of both maritime and nonmaritime claims. Litigants bringing claims under general federal jurisdiction are usually entitled to a jury trial; identical claims (maritime claims) brought under admiralty jurisdiction enjoy no such right. Dyer offers a proposal to determine whether a jury should be impaneled to hear a particular claim in a hybrid case.