Messier v. Bouchard Transportation
Plaintiff Richard Messier, a seaman, filed a maritime action against Bouchard Transportation Co., Inc., initially alleging negligence and unseaworthiness, and seeking maintenance and cure for B-cell lymphoma. Messier later dropped his Jones Act claim. The primary legal question was the definition of "manifest" for admiralty purposes: whether an asymptomatic illness contracted while in service but diagnosed later qualifies for maintenance and cure. The court denied Messier's motion for summary judgment and granted Bouchard's cross-motion, ruling that "manifest" requires the exhibition of symptoms while in the service of the ship. Additionally, the court rejected Messier's alternative theory that he was entitled to maintenance and cure for lymphoma because it manifested while he was potentially eligible for maintenance and cure for a back injury, as he was not actively receiving such benefits. As a result, Messier's motion for leave to amend his complaint was denied as moot.