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After voluntarily rescuing a vessel that was in peril on the high seas, Sea Tow/Sea Spill of Savannah, a marine towing service, filed an action in state court against the boat’s owner seeking a marine salvage award. The trial court dismissed the complaint, finding that Sea Tow’s claim could only be brought in federal admiralty court. The Court of Appeals of Georgia reversed,1 and we granted certiorari to consider whether Sea Tow could pursue a claim for marine salvage in state court. Because we find marine salvage is a remedy that is within the federal admiralty courts’ exclusive subject matter jurisdiction, we reverse the court of appeals’s contrary holding. However, we affirm the judgment because we conclude that Sea Tow’s complaint states a claim for quantum meruit, which is cognizable in state court.

According to the allegations in the complaint, in late May 1998, Robert Phillips abandoned his twenty-five foot sport fisherman boat, the Oosi Marine , after it capsized in the Atlantic Ocean, several miles off of the coast of Georgia. A few days later, Sea Tow located and rescued the vessel. Phillips knew that Sea Tow was searching for his vessel. Sea Tow subsequently sued Phillips for $15,000 based on its salvage services. The trial court dismissed the action, holding that Sea Tow’s claim was for “pure salvage which may only be prosecuted by an in rem action before a federal court sitting in admiralty.” In reversing, the court of appeals held that Sea Tow’s claim was “essentially a common law claim for quantum meruit for services rendered” and could be brought in state court.2

 
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