Pena v. Keystone Shipping Co.
Plaintiff Martin Pena, a worker aboard the S.S. DENALI but employed by Coastal Hydro Services, Inc., sued Keystone Shipping Co., the vessel owner, for personal injuries due to alleged negligence and unseaworthiness. Keystone filed a motion for summary judgment. The Court ruled that the Longshore and Harbor Workers Compensation Act (LHWCA) applied, which abolished the unseaworthiness claim against the vessel owner. Consequently, the Court granted summary judgment on the unseaworthiness claim, dismissing it with prejudice. However, the Court denied summary judgment on the LHWCA negligence claim, finding that while the evidence was tenuous, there was just enough to potentially establish a breach of Keystone's turnover duty related to insufficient lighting.