Douglas Daughtry v. Jenny G. LLC., 703 F. App'x 883

Background

Daughtry, a crewman, was injured aboard the fishing vessel Prince of Tides (owned and operated by Jenny G, LLC) and later had his leg amputated due to complications.
Jenny G, LLC purchased the vessel in 2010, paid the crew, and employed the captain who directed Daughtry; Gonzalez was the managing member of Jenny G, LLC.
Daughtry sued Gonzalez individually, Jenny G, LLC, and the vessel in rem under the Jones Act and general maritime law, alleging Gonzalez was his employer or the vessel owner.
Gonzalez moved for summary judgment asserting he was neither Daughtry’s employer nor the vessel’s owner and thus not liable under the Jones Act or maritime law.
Daughtry argued Gonzalez was liable under (1) the borrowed servant doctrine (as a direct employer) and (2) veil-piercing (Gonzalez used the corporation to shield personal liability), pointing to sale documents and the timing of the vessel sale and corporate dissolution.
The district court granted summary judgment for Gonzalez; the Eleventh Circuit affirmed, finding no factual dispute that Jenny G, LLC — not Gonzalez personally — employed Daughtry or owned the vessel, and that veil piercing and borrowed-servant theories failed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Gonzalez Daughtry’s Jones Act employer under the borrowed servant doctrine?	Gonzalez exercised control over vessel operations and thus was Daughtry’s employer or a borrowing employer.	Daughtry was hired, paid, and directed by Jenny G, LLC and its captain; Gonzalez did not control day-to-day work.	No — no evidence Gonzalez exercised the requisite control; borrowed-servant doctrine inapplicable.
Should the court pierce the corporate veil to hold Gonzalez personally liable for vessel ownership or employer status?	Jenny G, LLC was used as a liability shield; sale timing and documents show intent to avoid liability.	Corporate records and Coast Guard bills of sale show Jenny G, LLC owned and sold the vessel; Gonzalez acted as managing member; crew paid by the LLC.	No — plaintiff failed to show total domination, fraudulent use, or other exceptional circumstances to disregard the corporate form.
Are general maritime claims against Gonzalez viable without showing personal ownership of the vessel?	Gonzalez effectively owned or controlled the vessel and should be liable.	Ownership records attribute the vessel to Jenny G, LLC; no basis for attributing personal ownership to Gonzalez.	No — maritime claims fail because plaintiff did not prove Gonzalez personally owned the vessel or justify veil piercing.
Was summary judgment appropriate given the record?	Documentary timing and sale evidence create factual disputes for a jury.	The undisputed record (payroll, bills of sale, affidavits) negates plaintiff’s theories; speculation insufficient.	Yes — no genuine issue of material fact; summary judgment for Gonzalez affirmed.

Key Cases Cited

Nat’l Parks Conservation Ass’n v. Norton, 324 F.3d 1229 (11th Cir. 2003) (standard of review for summary judgment in the circuit)
Liese v. Indian River Cnty. Hosp. Dist., 701 F.3d 334 (11th Cir. 2012) (view evidence in light most favorable to nonmovant)
Focus on the Family v. Pinellas Suncoast Transit Auth., 344 F.3d 1263 (11th Cir. 2003) (movant’s burden to show absence of genuine dispute)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Sup. Ct.) (mere scintilla insufficient to defeat summary judgment)
Hurst v. Pilings & Structures, Inc., 896 F.2d 504 (11th Cir. 1990) (Jones Act claim depends on employment relationship)
Guidry v. S. Louisiana Contractors, Inc., 614 F.2d 447 (5th Cir.) (factors for determining seaman’s employer; borrowed servant doctrine)
Baker v. Raymond Int’l, Inc., 656 F.2d 173 (5th Cir.) (both payor and director can be Jones Act employers; focuses on control and payroll)
Gaudet v. Exxon Corp., 562 F.2d 351 (5th Cir.) (control as the key to borrowed-servant analysis)
Talen’s Landing, Inc. v. M/V Venture, II, 656 F.2d 1157 (5th Cir.) (veil piercing where corporations were undercapitalized, commingled, and lacked corporate separateness)
Cordoba v. Dillard’s, Inc., 419 F.3d 1169 (11th Cir. 2005) (speculation and conjecture cannot create genuine factual disputes)
Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (prior Fifth Circuit decisions binding precedent in Eleventh Circuit)