970 F.3d 550
5th Cir.2020Background
- Gilbert Sanchez, a welder hired by Smart Fabricators (SmartFab), worked 67 days for SmartFab and performed welding aboard jack-up drilling rigs owned by Enterprise Offshore Drilling.
- Time on relevant vessels: 48 days (72%) on ENTERPRISE WFD 350 (rig jacked up adjacent to a shoreside pier) and 13 days (19%) on ENTERPRISE 263 (on the Outer Continental Shelf).
- Sanchez returned home each evening (day shifts); his injury occurred on the ENTERPRISE 263 while working aboard a rig.
- Sanchez sued SmartFab in state court under the Jones Act; SmartFab removed; district court denied remand and granted summary judgment for SmartFab, holding Sanchez was not a seaman.
- The Fifth Circuit reviewed de novo and reversed: it held Sanchez satisfied the Chandris seaman test (duties + substantial connection in duration and nature) and remanded with instructions to return the case to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Sanchez a Jones Act "seaman"? | Sanchez performed ship's work and spent substantial time aboard Enterprise rigs, so qualifies | Work on jacked-up, dock‑adjacent rigs and daily return home show only a land‑based, sporadic connection | Reversed: Sanchez meets Chandris (duties + substantial connection in duration and nature); seaman status established |
Key Cases Cited
- Chandris, Inc. v. Latsis, 515 U.S. 347 (Sup. Ct.) (two‑prong seaman test: ship's work + substantial connection in duration and nature)
- Harbour Tug & Barge Co. v. Papai, 520 U.S. 548 (Sup. Ct.) (nature inquiry focuses on whether duties take employee to sea; exposure to seaborne perils required)
- McDermott Int’l, Inc. v. Wilander, 498 U.S. 337 (Sup. Ct.) (distinguishes land‑based workers from seamen; Jones Act v. LHWCA coverage)
- In re Endeavor Marine, Inc., 234 F.3d 287 (5th Cir.) (workers on moored/jacked vessels can be exposed to maritime perils and qualify as seamen)
- Naquin v. Elevating Boats, L.L.C., 744 F.3d 927 (5th Cir.) (work on docked/jacked vessels satisfies the nature prong when it exposes worker to maritime perils)