Chandris, Inc. v. Latsis
515 U.S. 347, 132 L. Ed. 2d 314, 1995 U.S. LEXIS 4047 (1995)
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Rule of Law:
To qualify as a 'seaman' under the Jones Act, a maritime worker's duties must contribute to the function of a vessel or the accomplishment of its mission, and the worker must have a connection to a vessel in navigation (or an identifiable group of vessels) that is substantial in terms of both its duration and its nature.
Facts:
- Antonios Latsis was employed by Chandris, Inc. as a superintendent engineer, responsible for the electronic and communications equipment on its fleet of six cruise ships.
- Latsis's duties required him to work both from a shore-based office in Miami and to take numerous voyages on the company's vessels.
- On May 14, 1989, while sailing aboard the S.S. Galileo in the course of his employment, Latsis developed a problem with his right eye.
- The ship's doctor diagnosed a suspected detached retina but failed to provide or arrange for immediate, emergency medical treatment, instead advising Latsis to wait until the ship docked in Bermuda two days later.
- Due to the delay in treatment, Latsis suffered a permanent 75% loss of vision in his right eye.
- After recuperating, Latsis returned to work and spent six months with the Galileo while it was in drydock in Germany for a major refurbishment.
- Latsis's employment with Chandris was terminated in November 1990.
Procedural Posture:
- Antonios Latsis filed suit against Chandris, Inc. in the U.S. District Court for the Southern District of New York for damages under the Jones Act.
- The district court instructed the jury that, in determining seaman status, it could not consider the period of time the vessel was in drydock.
- A jury returned a verdict for Chandris, Inc., finding that Latsis was not a seaman.
- Latsis, as appellant, appealed to the U.S. Court of Appeals for the Second Circuit.
- The Court of Appeals vacated the district court's judgment and remanded for a new trial, holding that the jury instructions were erroneous.
- Chandris, Inc., as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
To qualify as a 'seaman' under the Jones Act, must a maritime worker have an employment-related connection to a vessel in navigation that is substantial in terms of both its duration and its nature?
Opinions:
Majority - Justice O’Connor
Yes. To qualify as a 'seaman' under the Jones Act, a maritime worker must have an employment-related connection to a vessel in navigation that is substantial in terms of both its duration and its nature. The Court reasoned that the Jones Act is intended to protect sea-based maritime workers who are exposed to the 'perils of the sea,' not land-based workers with only a transitory connection to a vessel. The Court rejected a simple 'voyage test' in favor of a status-based inquiry. It established a two-part test: (1) the employee’s duties must contribute to the function of the vessel or to the accomplishment of its mission, and (2) the employee must have a connection to the vessel that is substantial in both its duration and its nature. This substantial connection requirement is essential to separate sea-based mariners from land-based workers. The Court further suggested a guideline that a worker spending less than 30% of their time in the service of a vessel in navigation would likely not qualify as a seaman. The Court also held that whether a vessel is 'in navigation' is a question of fact for the jury, and the district court erred by instructing the jury that the time the vessel spent in drydock could not be considered.
Concurring - Justice Stevens
Yes, but through a much simpler analysis. An employee of a ship who is injured at sea in the course of his employment is always a 'seaman' under the Jones Act. The majority's complex, status-based test is unnecessary and inappropriate for cases involving injuries on the high seas; it should be reserved for more ambiguous cases involving shore-bound work. The entire purpose of the Jones Act is to protect those who encounter 'the perils of the sea,' a category that unquestionably includes any crew member on a vessel during a voyage. The majority's concern that a worker might 'walk into and out of coverage' is irrelevant when an injury occurs on the open ocean, as the worker's status is clearly defined for the duration of that voyage.
Analysis:
This decision provides the definitive modern test for determining 'seaman' status under the Jones Act, clarifying the vague 'employment-related connection' standard from the Court's prior holding in Wilander. By establishing a two-part test requiring a substantial connection in both 'duration and nature,' the Court solidified the status-based approach over an activity-based 'voyage test.' The introduction of a quantitative, albeit non-binding, 30% rule of thumb for the duration element created a practical guideline for lower courts and employers, significantly impacting how maritime employment is classified for purposes of liability and insurance.
