Adams v. All Coast
988 F.3d 203
5th Cir.2021Background
- All Coast employed William Adams and other crew as mates, deckhands, ordinary seamen, and able‑bodied seamen aboard self‑propelled liftboats that service offshore oil platforms.
- Plaintiffs spent a substantial portion of work time—district court found between 25% and 90%—operating hydraulic cranes to move personnel and equipment between liftboats, docks, rigs, and other vessels; crane use occurred only while boats were jacked up/stationary.
- Plaintiffs lived aboard, ate and slept on the vessels, and performed traditional nautical duties when boats were underway or otherwise required.
- All Coast classified plaintiffs (including cooks) as exempt "seamen" under the FLSA and did not pay overtime; district court granted summary judgment for All Coast, concluding crane work "aids the vessel as a means of transportation."
- Fifth Circuit panel reversed: held crane operations while boats were stationary were not seaman work under 29 C.F.R. § 783.31 and related regulations; remanded for further proceedings, including reconsideration of cooks' exemption status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether operating liftboat cranes while jacked up is "seaman" work exempting plaintiffs from FLSA overtime | Crane operation is industrial/support work for rig customers, not maritime navigation; therefore non‑seaman work | Crane operation is integrated with vessel's transport function and necessary to liftboat mission and seaworthiness; therefore seaman work | Crane operation while the vessel was stationary is not seaman work; summary judgment for employer was improper |
| Whether plaintiffs' loading/unloading duties transform into seaman work because improper handling could affect vessel navigation | Loading/unloading to support customers is industrial and distinct from navigation; similar tasks on the rig would not be seaman work | Even loading/unloading that impacts vessel safety/efficiency can be seaman work if integrated with other maritime duties | Loading/unloading here resembled non‑seaman industrial work (Owens distinction); plaintiffs' crane duties were not sufficiently integrated with navigation to be exempt |
| Whether the 20% "substantial" guideline (29 C.F.R. § 783.37) disposes cooks' seaman status at summary judgment | Cooks spent substantial time preparing food for non‑crew or for crew during non‑seaman work, so they are non‑seamen entitled to overtime | Cooks ordinarily qualify as seamen because they feed a vessel crew and their work is part of vessel operation | District court must reassess cooks on remand using the 20% guideline and factual record about how much time was spent serving non‑seamen/serving crew during non‑seaman periods |
| Appropriateness of summary judgment given factual disputes about time allocation and character of work | Plaintiffs argued genuine disputes on percent of time and character of crane/cook work preclude summary judgment | All Coast argued undisputed evidence supports seaman exemption as a matter of law | Summary judgment reversed; factual issues (time allocation, what constitutes "substantial" differing work) require further proceedings and possibly a jury determination |
Key Cases Cited
- Coffin v. Blessey Marine Servs., Inc., 771 F.3d 276 (5th Cir. 2014) (articulates two‑part seaman exemption test and weighs regulatory guidance on integrated duties)
- Owens v. SeaRiver Maritime, Inc., 272 F.3d 698 (5th Cir. 2001) (loading/unloading on a permanently moored barge held non‑seaman work; rejects overly broad "aid in operation" test)
- Walling v. W.D. Haden Co., 153 F.2d 196 (5th Cir. 1946) (early articulation that "seaman" hinges on the character of duties, not job title)
- Dole v. Petroleum Treaters, Inc., 876 F.2d 518 (5th Cir. 1989) (gives Department of Labor regulations great weight in FLSA seaman analyses)
- Martin v. Bedell, 955 F.2d 1029 (5th Cir. 1992) (cook is usually a seaman but court must determine whether substantial non‑seaman work—guided by ~20% rule—negates exemption)
- W.D. Haden Co. (as discussed in opinion) captured in Walling precedent above
- Harkins v. Riverboat Servs., Inc., 385 F.3d 1099 (7th Cir. 2004) (distinguishes shipboard operational crew from concessionaires/stationary entertainment staff; asks whether duties are necessary because the vessel is a ship or because of its business)
- Encino Motorcars, L.L.C. v. Navarro, 138 S. Ct. 1134 (2018) (Supreme Court: FLSA exemptions receive a fair—not unduly narrow—reading)