Stewart v. Dutra Construction Co.
543 U.S. 481, 2005 U.S. LEXIS 1397, 160 L. Ed. 2d 932 (2005)
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Rule of Law:
A watercraft qualifies as a 'vessel' under the Longshore and Harbor Workers’ Compensation Act (LHWCA) if it is used, or is practically capable of being used, as a means of transportation on water. This determination is not dependent on the watercraft's primary purpose or its movement at the time of injury.
Facts:
- Dutra Construction Company owned the 'Super Scoop,' a large dredge used for the 'Big Dig' tunnel project in Boston Harbor.
- The Super Scoop had navigational lights and a crew but lacked significant self-propulsion, being towed for long distances and moving short distances by manipulating anchors and cables.
- Dutra hired Willard Stewart as a marine engineer to maintain the Super Scoop's mechanical systems.
- While the Super Scoop was temporarily idle, Stewart was working aboard an adjacent scow that had suffered an engine malfunction.
- Stewart was positioned next to an open hatch on the scow, feeding wires into the engine area.
- The Super Scoop used its bucket to move the scow, causing a collision between the two.
- The jolt from the collision caused Stewart to fall headfirst through the hatch, resulting in serious injuries.
Procedural Posture:
- Willard Stewart sued Dutra Construction Company in the U.S. District Court for the District of Massachusetts, asserting claims under the Jones Act and the LHWCA.
- The District Court granted summary judgment to Dutra on the Jones Act claim, holding the Super Scoop was not a vessel.
- On interlocutory appeal, the U.S. Court of Appeals for the First Circuit affirmed the summary judgment.
- On remand, the District Court granted summary judgment to Dutra on Stewart's remaining LHWCA negligence claim.
- The U.S. Court of Appeals for the First Circuit affirmed this second summary judgment.
- The U.S. Supreme Court granted certiorari to resolve confusion over the definition of a 'vessel'.
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Issue:
Is a dredge, which has limited means of self-propulsion and is primarily used for construction, a 'vessel' under the Longshore and Harbor Workers’ Compensation Act (LHWCA)?
Opinions:
Majority - Justice Thomas
Yes, a dredge is a 'vessel' under the LHWCA. The controlling definition comes from 1 U.S.C. § 3, which defines a vessel as 'every description of water-craft or other artificial contrivance used, or capable of being used, as a means of transportation on water.' This broad definition, which codifies long-standing general maritime law, includes special-purpose watercraft like dredges. The Court rejected the lower court's test that focused on the craft's primary purpose and whether it was in motion at the time of the injury. The proper inquiry is whether the watercraft is practically capable of maritime transport, not whether transportation is its main job. The Super Scoop was used to transport equipment and crew over water in the course of its dredging work and had not been permanently withdrawn from service, so it qualifies as a vessel.
Analysis:
This decision resolves a circuit split and establishes a clear, broad, and uniform definition of 'vessel' for the Jones Act and LHWCA. By rejecting purpose-based or 'snapshot' tests that analyzed a craft's activity at the moment of injury, the Court provided a more stable and predictable standard. This expands the scope of what constitutes a vessel to include many special-purpose watercraft, potentially affording Jones Act seaman status to a wider range of maritime workers on structures like dredges, barges, and floating platforms, so long as they are practically capable of navigation.
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