Chandris, Inc. v. Latsis 515 U.S. 347
- Category: Seaman injuries; Jones Act
- Holding: 9-0 for the respondent/plaintiff.
- 515 US 347; 94-325
The respondent in this case (Latsis) was an engineer for a shipping company, Chandris Inc. While working aboard one of its ships, he develop a condition in one of its eyes. This condition was allowed to go untreated by the vessel’s onboard physician and soon deteriorated rapidly. The injury caused him great distress and injury. To recover for this incident, Latsis sued Chandris for the damages that ensued from the eye pain under the Jones Act.
The Jones Act provides protections to seamen for negligently caused injuries incurred in the scope of employment. The district court decided this case on the premises that a person is considered a seaman if he or she is permanently aboard or contributes to the mission of the ship. The Second Circuit Court of Appeals vacated this judgment on the issue of the definition of seaman and the petitioner eventually brought this case to the Supreme Court where it received certiorari.
Was the petitioner/plaintiff a seaman entitled to protections under the Jones Act? Did the time that the petitioner/plaintiff spent on the docks count towards his status as a seaman to qualify for protections under the Jones Act?
The heart of this case was the Jones Act. This Act guarantees protections and a cause of action to seamen that are negligently injured on the job. However, the issue of who is and who is not a seaman emerged in this case as it had in others. Prior to Chandris, there were competing definitions for the term seaman.
The Court in Robinson offered its own rule when it stated that a seaman must contribute to the mission of the shop. In Johnson, the Court stated that a seaman must make a significant contribution.
Finally, in Wilander, the court refuted the notion that a seaman must act to further the ship’s mission or help in navigation. Also, prior courts were split on how to handle the time that Latsis actually spent on the docks, though he was working, the ship was not in
The Court in Robinson offered its own rule when it stated that a seaman must contribute to the mission of the shop. In Johnson, the Court stated that a seaman must make a significant contribution. Finally, in Wilander, the court refuted the notion that a seaman must act to further the ship’s mission or help in navigation. Also, prior courts were split on how to handle the time that Latsis actually spent on the docks, though he was working, the ship was not in voyage.
The Court took a complicated approach when ruling on the issue of what constitutes a seaman. It decided on a two-prong rule. First, seamen must contribute to the function of a vessel. Second, seamen must have a significant connection to a “vessel in navigation.” Both of these legal issues are fact-intensive and rely on a jury to use the facts and circumstance of each incident to determine if the person was or was not a seaman for the purposes of a Jones Act lawsuit.
In certain situations, it is readily apparent that someone is or is not a seaman and in those circumstances a judge can take the issue away from a jury. Yet, in many other times, it is not so close and then a judge must let the jury decide. Generally, courts look to whether or not a person works aboard a vessel more or less than thirty percent of his or her time before deciding on the issue as a matter of law.
In this case, because the lower courts utilized an improper definition of the term seaman but the Appellate Court used an acceptable form, that part of the decision was affirmed. However, the Supreme Court took exception with the lower courts summary dismissal of the idea that time spent on a dock could not count as “in navigation.” It stated that this fact-heavy matter must be taken up by a jury unless it is patently obvious that the ship was not “in navigation.” There was no such clarity here and thus this point was to be reconsidered.
People qualify as seaman and are entitled to the protections of the Jones Act if they contribute to the function of a vessel and have a significant connection to the “vessel in navigation.”
The decision of this Court was unanimous (Rehnquist, Stevens, O’Connor, Scalia, Kennedy, Souter, Thomas, Ginsburg, and Breyer).
This case added great clarity to the meaning of the Jones Act, an act that provides important protections for seamen. The Act stated what they were entitled to but did not outline in great detail whom was entitled to it. This case did that and rose above the competing versions offered in the past to offer a clear definition.
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