Magana v. Hammer & Steel, Inc.
The plaintiffs, Rodrigo and Maria Magana, filed a personal injury lawsuit against Robert B. Miller & Associates (barge owner), Hammer & Steel, Inc. (steel supplier), and Poston Industrial Maintenance Company, Inc. (coating applicator) after Rodrigo Magana was severely injured by a falling chunk of concrete while unloading a steel piling sheet from a barge in the Houston Ship Channel on January 4, 2001. Defendants Miller and Hammer filed motions to dismiss for lack of subject matter jurisdiction, arguing the claims lacked admiralty flavor. The Court, presided over by District Judge Kent, denied both motions. While finding that 33 U.S.C. § 905(b) and Article III admiralty jurisdiction were not directly applicable, the Court determined it had jurisdiction over Miller via the Admiralty Extension Act (AEA), 46 App. U.S.C. § 740, because the injury was caused by a vessel or its appurtenance (the concrete). Supplemental jurisdiction under 28 U.S.C. § 1367 was found for the claims against Hammer and Poston due to their relation to the claims against Miller. The Court ordered Plaintiffs to file an Amended Complaint to specify the governing law for each cause of action against each defendant.