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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Seemann v. Coastal Environmental Group, Inc.

Plaintiff Johnny Seemann filed an action against Coastal Environmental Group, Inc., alleging injuries from an unseaworthy barge and negligence under the Jones Act and general maritime law. Seemann sought to amend his complaint to add GSI Disaster Services, Inc., as a defendant. District Judge Spatt, presiding over the case in the Eastern District of New York, granted in part and denied in part this motion. The Court denied adding Jones Act negligence and maintenance and cure claims against GSI, finding GSI was not Seemann's employer. However, the motion to add an unseaworthiness claim against GSI was granted, as the presence of ice on the vessel's deck plausibly suggested an unseaworthy condition, a claim for which strict liability applies to the vessel owner.

Jones ActMaritime LawUnseaworthinessNegligenceMotion to AmendFederal Rules of Civil Procedure 15Rule 12(b)(6)Seaman InjuryBarge AccidentEmployer Liability
References
60
Case No. MISSING
Regular Panel Decision
Mar 18, 2010

Scoran v. Overseas Shipholding Group, Inc.

Plaintiff Jason N. Scoran, a Second Mate on the vessel Overseas New Orleans, suffered a compound leg fracture after falling into an unprotected swash hole in a fuel tank during cleaning operations in 2006. He filed a Jones Act claim alleging negligence and unseaworthiness, also seeking maintenance and cure. Plaintiff moved for partial summary judgment, seeking to dismiss defendants' comparative and third-party negligence defenses, and a finding that the vessel was unseaworthy as a matter of law due to the unguarded hole and alleged violations of work-hour regulations. The court denied plaintiff's motion for partial summary judgment in all respects, finding genuine issues of material fact regarding the comparative negligence defense and the unseaworthiness claim, and declining to apply the Pennsylvania Rule for causation.

Jones ActMaritime LawSeaworthinessComparative NegligenceSummary JudgmentShipboard AccidentFuel TankGuard RailsWorking HoursVessel Safety
References
43
Case No. MISSING
Regular Panel Decision
Mar 24, 1989

Marroquin v. American Trading Transportation Co.

Plaintiff Edmundo S. Marroquin was injured on November 8, 1985, while cleaning a cargo tank aboard the S.S. Washington Trader on the high seas. Marroquin was employed by third-party defendant Stevens Technical Services and the vessel was owned by defendant and third-party plaintiff American Trading Transportation Company. Marroquin initially sued American Trading for negligence and later added a cause of action for unseaworthiness. American Trading then instituted a third-party action for contribution and indemnification against Stevens. Stevens moved for summary judgment, arguing that Marroquin's unseaworthiness claim was barred by the Longshore and Harbor Workers’ Compensation Act (LHWCA), which would also dismiss American Trading's third-party action. The court denied Stevens' motion, finding that Marroquin was not covered by the LHWCA because he was the equivalent of a 'member of a crew' working on the high seas, not a land-based worker in port. Additionally, the LHWCA's geographical scope does not extend to injuries on the high seas during a long international voyage. Therefore, Marroquin could maintain his unseaworthiness claim, and American Trading could seek contribution or indemnification from Stevens.

Maritime LawUnseaworthiness ClaimLHWCA InapplicabilityHigh Seas InjurySeaman StatusThird-Party ActionSummary Judgment MotionVessel Cleaning CrewContribution and Indemnification
References
17
Case No. MISSING
Regular Panel Decision
Jun 27, 2001

Emanuel v. Sheridan Transportation Corp.

James Emanuel, an employee of G. Marine Diesel Corp., suffered fatal injuries after falling from a gangway while working on the barge ST 114, owned by Amerada Hess and operated by Spentonbush/Red Star Companies, Inc., which was in dry dock for repairs. His estate sued, alleging negligence and unseaworthiness. The trial court found the defendants negligent and the barge unseaworthy, awarding substantial damages. The appellate court reversed the judgment, finding errors in the jury instructions regarding seaworthiness and negligence under the LHWCA and Jones Act, and remanded for a new trial. The court clarified the limited duties of vessel owners to longshoremen and other harbor workers post-1972 LHWCA amendments.

Maritime LawWorkers' CompensationLongshore and Harbor Workers’ Compensation Act (LHWCA)Jones ActNegligenceSeaworthinessVessel Owner LiabilityShipyard OperationsDry Dock AccidentGangway Safety
References
42
Case No. MISSING
Regular Panel Decision

Turner v. Niagara Frontier Transportation Authority

Plaintiff Emmett L. Turner was severely injured after an accident on the vessel "Samuel Wilkeson," where he tripped and fell through an open hatch, resulting in quadriplegia. He sued his employer, Niagara Frontier Transportation Authority (NFTA), and the vessel owner, City of Buffalo, alleging negligence and unseaworthiness. The City moved for summary judgment, arguing it was not Turner's employer and had relinquished control of the vessel through a charter. The court denied the City's motion, finding genuine issues of material fact regarding its potential liability for both negligence and unseaworthiness, especially concerning defects present prior to the charter agreement. Additionally, the NFTA's motion to amend its answer to include a defense of waiver of federal remedies due to the plaintiff's acceptance of state workers' compensation was also denied, as there was no evidence of an unqualified waiver.

Maritime LawUnseaworthinessNegligenceJones ActSummary JudgmentWorkers' CompensationVessel CharterOwner LiabilityFederal Rules of Civil ProcedurePersonal Injury
References
41
Case No. MISSING
Regular Panel Decision

Anastasiou v. M/T WORLD TRUST

Plaintiff John Anastasiou sued World-Wide Shipping Agency, Garlan Company, Moran Shipping Agencies, and World Trust under general maritime law for breach of seaworthiness and negligence. Anastasiou, a marine electronics technician, suffered a broken leg after slipping on a wet ramp while boarding the Vessel World Trust to perform a radio safety survey on January 20, 2001. Defendants moved for summary judgment, arguing the claim for unseaworthiness was precluded by the Longshore and Harbor Workers’ Compensation Act (LHWCA), and there was no evidence of negligence. The Court granted summary judgment, finding Anastasiou was covered by the LHWCA, which bars unseaworthiness claims, and that no genuine issue of material fact supported the negligence claim, as the dangerous condition of the ramp was obvious, and no prior notice of a defect was proven.

Maritime LawLongshore and Harbor Workers’ Compensation ActSeaworthinessNegligence ClaimSummary JudgmentVessel InjurySlip and FallRadio Safety SurveyMarine Electronics TechnicianDuty of Care
References
46
Case No. MISSING
Regular Panel Decision

Salamon v. Motor Vessel Poling Bros. No. 11, Inc.

Plaintiff Romolo Salamon, a cook, sued defendant Motor Vessel Poling Bros. No. 11, Inc. (Poling) for personal injuries under unseaworthiness and Jones Act negligence theories after slipping on a stairway owned by Automatic Comfort Corp. Poling impleaded Automatic Comfort, and Salamon later amended his complaint to include Automatic Comfort. Poling moved for dismissal, and Salamon cross-moved for summary judgment. The court granted Poling's motion to dismiss the unseaworthiness claim, finding no defect in the ship or its equipment. However, the court denied Poling's motion to dismiss the negligence claim under the Jones Act, stating there was a factual issue regarding Poling's duty to provide a safe place to work given the stairway's proximity and frequent use. Plaintiff's cross-motion for summary judgment was denied.

Maritime LawJones ActUnseaworthinessPersonal InjuryNegligenceSummary JudgmentDismissal MotionThird-Party ComplaintSeaman's RightsSafe Place to Work
References
9
Case No. MISSING
Regular Panel Decision

Gaymon v. Prudential Lines, Inc.

Plaintiff George Gaymon suffered personal injuries as a longshoreman on a barge in Port Newark in 1972, suing Prudential Lines, Inc. for negligence and unseaworthiness, and McAllister Bros., Inc. for negligence due to a collision. Prudential cross-claimed against McAllister and filed a third-party action against United Terminals, Inc. for indemnity. The initial claims against Prudential and United were dismissed. McAllister was found liable to Gaymon, and they settled. Prudential then moved to amend the judgment to recover attorneys' fees and costs from McAllister based on an implied warranty of workmanlike service in a towage contract. The court denied Prudential's motion, concluding that Ryan indemnity, which requires a shipowner's exposure to liability without fault due to a contractor's breach, did not apply since McAllister merely ran into the barge without creating an unseaworthy condition exposing Prudential to such liability.

Implied Warranty of Workmanlike ServiceLongshoremen and Harbor Workers' Compensation ActIndemnity ClaimTowage ContractMaritime LawFederal Rules of Civil ProcedureVessel CollisionNegligenceUnseaworthinessAttorneys' Fees
References
11
Case No. MISSING
Regular Panel Decision

American Dredging Co. v. Plaza Petroleum Inc.

Plaintiff American Dredging Company (ADC) purchased 38,000 gallons of fuel, which was supplied by Plaza Petroleum Inc. and Kerr McGee Refining Corporation, Inc. (KMRC) and transported by Eklof Marine Corp. The fuel was allegedly contaminated, causing ADC economic damages from repairs and lost income. ADC filed suit against all three parties, invoking the admiralty jurisdiction of the court, alleging negligence and unseaworthiness. The court addressed these claims de novo, vacating portions of a prior order. It concluded that a general maritime duty of unseaworthiness was not applicable without personal injury or a direct contractual relationship with the carrier. Furthermore, the court determined that a negligence claim seeking purely economic loss is not maintainable in admiralty, aligning with the principles established in East River Steamship Corp. Consequently, the court granted summary judgment in favor of all defendants, dismissing ADC's claims.

Admiralty jurisdictionEconomic lossNegligence claimUnseaworthiness claimSummary judgmentFuel contaminationMaritime lawContract vs. TortProducts liabilityCarriage of Goods by Sea Act
References
17
Case No. MISSING
Regular Panel Decision

Caldaro v. Float No. 187

The libelant, employed as a stowman on Float No. 187, was injured due to the vessel's unseaworthy condition and subsequently filed a libel. This action follows a previous case where the libelant sued his employer, Baltimore and Ohio Railroad Company, for the same injuries. In that prior action, the complaint was dismissed, with Judge J. Edward Lumbard ruling that the Longshoremen's and Harbor Workers' Compensation Act provided the exclusive remedy. Citing a similar precedent, the court in the present case sustained the respondent's exceptions to the libel, leading to its dismissal.

Seaman InjuryUnseaworthinessLongshoremen's and Harbor Workers' Compensation ActExclusive RemedyAdmiralty LawMaritime LawLibelExceptionsCase DismissalFederal District Court
References
4
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