Naquin v. Elevating Boats, LLC
842 F. Supp. 2d 1008
E.D. La.2012Background
- Elevating Boats, LLC designs, builds, and operates lift boats and cranes; Naquin worked at the Houma facility since 1997 in multiple roles, including repair supervisor and deckhand duties; he spent substantial time aboard vessels and on deck for repairs, inspections, and mooring; he occasionally went to sea for brief sea trials and offshore crane work; an accident on a land-based crane caused injuries, with Longshore and Harbor Workers’ Compensation benefits paid thereafter; Plaintiff sued under the Jones Act, reserving rights under the LHWCA, and Defendant moved for summary judgment alleging Naquin is not a seaman and thus not covered by the Jones Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Naquin is a Jones Act seaman under Chandris prong 1. | Naquin’s deckhand duties and vessel-related tasks contributed to the vessel’s function. | Naquin’s duties were maintenance/repair with only indirect relation to the vessels’ missions. | Prong 1 satisfied; Naquin’s duties contribute to vessel function. |
| Whether Naquin has a substantial connection to a vessel in navigation under Chandris prong 2. | Naquin spent substantial time on vessels and performed deckhand duties; testified to offshore work. | Time aboard vessels was minimal and mostly shore-based; connection not substantial. | Issue of prong 2 triable; summary judgment improper. |
Key Cases Cited
- Chandris v. Latsis, 515 U.S. 347 (1995) (two-prong test for seaman status: function and connection to vessel)
- Harbor Tug & Barge Co. v. Papai, 520 U.S. 548 (1997) (seaman status; going to sea interpretation and exposure to perils)
- In re Endeavor Marine, Inc., 234 F.3d 287 (5th Cir. 2000) (going-to-sea test; not sole determinant for seaman status)
- Becker v. Tidewater, Inc., 335 F.3d 376 (5th Cir. 2003) (30% time rule for substantial connection in fleets)
- Roberts v. Cardinal Servs., Inc., 266 F.3d 368 (5th Cir. 2001) (fleet context; 30% rule with common ownership/control)
- Sieracki ( Seas Shipping Co. v. Sieracki ), 328 U.S. 85 (1946) (perils of the sea and seaman status principles)
- Legros v. Panther Servs. Group, Inc., 863 F.2d 345 (5th Cir. 1988) (navigation connection and exposure to sea-related hazards)
- Scheuring v. Traylor Bros., Inc., 476 F.3d 781 (9th Cir. 2007) (sea-based duties near navigation site can create seaman status)