Keith Coffin v. Blessey Marine Services, In
771 F.3d 276
| 5th Cir. | 2014Background
- Blessey challenges the district court’s denial of summary judgment on whether nine vessel-based tankermen were exempt seamen under the FLSA.
- The plaintiffs loaded and unloaded liquid cargo on a unit tow and were part of the towboat crew aboard barges towed by Blessey’s vessels.
- The district court had treated loading/unloading as nonseaman work as a matter of law, relying on Owens v. SeaRiver and certifying a class that remained largely opt-in but was pursued individually.
- Blessey introduced evidence that loading/unloading was integrated with navigational duties and essential to seaworthiness and safe operation of the unit tow.
- Plaintiffs argued loading/unloading is nonseaman work; Blessey argued it is seaman work because it is performed by vessel-based crew and tied to the vessel’s operation.
- The court reviews a summary judgment ruling de novo to determine whether the seaman exemption applies to these vessel-based tankermen.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether loading/unloading by vessel-based tankermen is seaman work | Owens controls, loading/unloading generally nonseaman work | Facts show duties integrated with navigation; seaman work under §783.31 | Yes; loading/unloading can be seaman work for these plaintiffs |
| Whether Owens forecloses a factual inquiry into the nature of loading/unloading duties | Owens bars seaman characterization for these duties | Owens distinguished; context matters; not controlling here | Owens not controlling; context matters; summary judgment improper |
| Whether the tankermen were ordinary seamen under 29 C.F.R. § 783.31 | Tankermen perform nonseaman tasks; not full crew | Tankermen are part of the vessel crew; their duties aid navigation | Tankermen are seamen; loading/unloading is integrated with voyage duties |
| Application of the regulation 29 C.F.R. § 783.36 and related standards to this context | § 783.36 supports nonseaman classification for loading/unloading | Regulations are not categorical; context matters per § 783.33 | Regulations support seaman status where duties are integrated with navigational mission |
Key Cases Cited
- Owens v. SeaRiver Maritime, Inc., 272 F.3d 698 (5th Cir. 2001) (fact-specific seaman exemption; distinguishes land-based vs vessel-based work)
- Gale v. Union Bag & Paper Corp., 116 F.2d 27 (5th Cir. 1940) (crewmembers on barges deemed seamen; essential to operation)
- Martin v. Bedell, 955 F.2d 1029 (5th Cir. 1992) (crewmembers like cooks may be seamen; context dictates status)
- Dalheim v. KDFW–TV, 918 F.2d 1220 (5th Cir. 1990) (fact-intensive seaman exemption analysis)
- Christopher v. SmithKline Beecham Corp., 132 S. Ct. 2156 (S. Ct. 2012) (statutory interpretation; includes illustrative, not exhaustive, examples)
- Walling v. W. D. Haden Co., 153 F.2d 196 (5th Cir. 1946) (dredge context; not all vessel work is seaman work)
- Harkins v. Riverboat Servs., Inc., 385 F.3d 1099 (7th Cir. 2004) (context and crew status influence seaman exemption)