Hartley v. Peter Kiewit Sons' Co.
Plaintiff James Hartley sustained personal injuries while employed by Peter Kiewit Sons' Co. during bridge construction in Troy, New York. He filed two consolidated actions: one against Kiewit under the Jones Act for bodily injury and loss of earnings, and another against Home Indemnity Company, Kiewit's workers' compensation insurer, alleging denial of LHWCA benefits after receiving New York State benefits. Defendants moved for summary judgment, arguing Hartley's injury was covered by neither the Jones Act nor LHWCA. The court granted summary judgment for Home Indemnity, dismissing the LHWCA claim based on precedents that Hartley's construction activities were not considered "maritime employment" under the Act. However, the court denied Kiewit's motion to dismiss the Jones Act claim, finding a sufficient evidentiary basis for Hartley to potentially qualify as a "seaman," thus allowing that claim to proceed to trial.