McDermott International, Inc. v. Wilander

Supreme Court of the United States
498 U.S. 337, 112 L. Ed. 2d 866, 1991 U.S. LEXIS 1046 (1991)

ELI5:

Rule of Law:

An employee's duties must contribute to the function of the vessel or the accomplishment of its mission to qualify as a 'seaman' under the Jones Act; the employee is not required to aid in the navigation of the vessel.

Facts:

Jon Wilander worked for McDermott International, Inc., as a paint foreman.
His duties involved supervising the sandblasting and painting of fixtures on oil drilling platforms in the Persian Gulf.
Wilander was assigned to the MW Gates Tide, a 'paint boat' that contained the equipment used for the sandblasting and painting work.
On July 4, 1983, while inspecting a pipe on an oil platform, a pressurized bolt blew out and struck Wilander in the head, causing injury.

Procedural Posture:

Jon Wilander sued McDermott International, Inc. in the U.S. District Court for the Western District of Louisiana, seeking recovery under the Jones Act.
The District Court denied McDermott's motion for summary judgment, which argued that Wilander was not a 'seaman' as a matter of law.
In a bifurcated trial, a jury first determined that Wilander met the test for seaman status.
The case then proceeded to a trial on liability, where the jury found McDermott negligent and awarded damages to Wilander.
The District Court denied McDermott's motion for judgment notwithstanding the verdict.
McDermott, as appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit, which affirmed the district court's judgment, upholding its test for seaman status.
The U.S. Supreme Court granted McDermott's petition for certiorari to resolve a conflict among the circuit courts on the proper test for seaman status.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does an employee need to aid in the navigation of a vessel to qualify as a 'seaman' under the Jones Act?

Opinions:

Majority - Justice O'Connor

No. An employee does not need to aid in the navigation of a vessel to qualify as a 'seaman' under the Jones Act. The Jones Act uses the term 'seaman' as it was understood in general maritime law at the time of its passage, which had evolved to include all persons employed on board a vessel to promote the purposes of its voyage, not just those who could 'hand, reef and steer.' The court traces the history of the term, noting that while early cases required an 'aid in navigation,' this requirement was abandoned by the late 19th century in favor of a broader test focused on furthering the vessel's mission. The Longshore and Harbor Workers’ Compensation Act (LHWCA) created a distinction between land-based and sea-based workers, confining Jones Act benefits to the latter, identified as the 'master or member of a crew.' This term is functionally equivalent to 'seaman.' The Court explicitly jettisons the 'aid in navigation' language that had crept back into case law through inconsistent interpretations of the LHWCA, and instead adopts the Fifth Circuit's standard from Offshore Co. v. Robison. The key to seaman status is an employment-related connection to a vessel in navigation, where the employee's work contributes to the function of the vessel or the accomplishment of its mission.

Analysis:

This decision resolved a significant circuit split, establishing a uniform, modern standard for determining seaman status under the Jones Act. By explicitly rejecting the narrow 'aid in navigation' requirement, the Court broadened the scope of workers eligible for Jones Act remedies, particularly those on specialized vessels like drilling rigs, barges, and other floating platforms whose primary purpose is not transportation. The ruling shifts the focus of the inquiry from the employee's specific duties to their overall connection to the vessel and its mission. This provides a more flexible framework that reflects the modern realities of maritime employment and ensures protection for all sea-based workers exposed to the 'perils of the sea.'

🤖 Gunnerbot:

Query McDermott International, Inc. v. Wilander (1991) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.

Subscribe to Lexplug to chat with the Gunnerbot about this case.

Premium Feature