Holloway v. Pagan River Dockside Seafood, Inc.
669 F.3d 448
| 4th Cir. | 2012Background
- Holloway sues under the Jones Act alleging he was a seaman employed by Pagan River and Melzer and injured on the job.
- Holloway claimed he 'leased' a Pagan River boat and was paid per catch, with a fee for vessel use, suggesting a maritime employment relationship.
- The injury occurred on December 8, 2009, while Holloway assisted unloading oysters, allegedly due to conveyor belt negligence.
- Pagan River and Melzer moved to dismiss under Rules 12(b)(1) and 12(b)(6), arguing Holloway was not a seaman and his injury was not in the course of seaman employment.
- The district court granted the motion, concluding Holloway had not shown seaman status or that the injury occurred in the course of employment.
- The Fourth Circuit reversed, holding there was federal subject matter jurisdiction and remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court had subject matter jurisdiction under the Jones Act | Holloway contends the claim is colorable and warrants federal jurisdiction. | Defendants contend Holloway did not show seaman status or course-of-employment facts. | Yes; court held jurisdiction exists and case must be remanded for development. |
| Whether seaman status and course of employment should be resolved at this stage | Facts support seaman status and connection to a vessel. | Record insufficient or mischaracterized regarding seaman status. | Record development required; jurisdiction remains and 12(b)(1) dismissal inappropriate. |
Key Cases Cited
- Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (Supreme Court 1998) (drive-by jurisdictional rulings discouraged)
- Arbaugh v. Y & H Corp., 546 U.S. 500 (Supreme Court 2006) (distinguishes jurisdictional rulings from merits)
- Oneida Indian Nation of N.Y. v. County of Oneida, 414 U.S. 661 (Supreme Court 1974) (jurisdiction not defeated by potential failure to state a claim)
- Romero v. Int'l Terminal Operating Co., 358 U.S. 354 (Supreme Court 1959) (supremacy of federal jurisdiction to resolve Jones Act claims)
- McLaughlin v. Boston Harbor Cruise Lines, Inc., 419 F.3d 47 (1st Cir. 2005) (seaman status typically decided after trial; factual issue)
- Wheatley v. Gladden, 660 F.2d 1024 (4th Cir. 1981) (employer/employee relationship must be determined under maritime law)
- O'Donnell v. Great Lakes Dredge & Dock Co., 318 U.S. 36 (Supreme Court 1943) (maritime jurisdiction and jury right considerations)