Kenning v. Bludco Barge & Towing Co.
Randall Kenning appealed a take-nothing summary judgment in his suit against former employer Bludco Barge and Towing Company and Central American Barge & Towing Company. Kenning sued under the Jones Act, LHWCA, and general maritime law, claiming personal injury from toxic chemical exposure while repairing a cargo seal on a barge. The court affirmed the summary judgment, ruling that Kenning did not qualify as a Jones Act seaman as he was not permanently assigned to a vessel nor did a substantial part of his work occur on a vessel. Furthermore, the warranty of seaworthiness did not extend to him as he was tasked with repairing the known unseaworthy condition that allegedly caused his injuries. Kenning waived his LHWCA negligence claim during oral argument.