Brunetti v. Cape Canaveral Shipping Co., SA
Peter Brunetti, a longshoreman, sued Cape Canaveral Shipping Company, S.A., a shipowner, for personal injuries. Canaveral moved for summary judgment, arguing the suit was barred under the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA) Section 33(b) because Brunetti had accepted compensation under a Memorandum of Informal Conference, which Canaveral contended operated as an assignment of his rights. The court, reexamining prior Second Circuit decisions in light of the Supreme Court's Pallas Shipping Agency Ltd. v. Duris (1983) and the Third Circuit's Costa v. Danais Shipping Co. (1983), determined that a Memorandum of Informal Conference, absent a formal compensation order, does not constitute an "award in a compensation order" sufficient to trigger the assignment provisions of LHWCA Section 33(b). Consequently, the motion for summary judgment was denied.