Sanchez v. Enterprise Offshore Drilling LLC, 4:19-cv-00110

Plaintiff Gilbert Sanchez, a welder, injured his ankle and back in Aug. 2018 while working on the Enterprise 263 drilling rig owned by Enterprise Offshore Drilling; Sanchez’s employer was Smart Fabricators of Texas.
Smart Fabricators had paid Sanchez LHWCA workers’ compensation benefits before Sanchez sued in state court in Dec. 2018 asserting a Jones Act negligence claim and a general maritime unseaworthiness claim; defendants removed to federal court in Jan. 2019.
Sanchez dismissed claims against Enterprise Offshore Drilling and moved to remand; the court denied remand because Sanchez offered no evidence proving he was a Jones Act seaman.
Smart Fabricators moved for summary judgment asserting that, because Sanchez is not a seaman, his exclusive remedy is LHWCA benefits and tort claims (Jones Act and unseaworthiness) against his employer fail.
Sanchez relied largely on a brief affidavit claiming he performed construction, maintenance, and welding; Smart Fabricators submitted testimony that Sanchez worked on rigs while they were jacked up above the water and not exposed to waves/tides.
The court found Sanchez failed to raise a genuine factual dispute that his connection to the vessels was substantial in nature and granted Smart Fabricators’ summary judgment motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sanchez is a Jones Act seaman (substantial-connection, nature prong)	Duties as a welder aboard vessels exposed him to perils of the sea; Naquin supports that routine maintenance can be seaman work	Sanchez worked only on rigs jacked up out of the water and did not perform vessel-navigation or crew functions; thus no substantial connection in nature	Sanchez failed to raise a genuine dispute on the nature prong; not a seaman; summary judgment for Smart Fabricators
Whether Sanchez’s remedy is Jones Act/unseaworthiness vs. LHWCA exclusive remedy	Jones Act applies if seaman; seeks tort remedies	If not a seaman, LHWCA is exclusive remedy and employer is immune from tort suit	Because Sanchez is not a seaman, his exclusive remedy is LHWCA; tort claims dismissed

Chandris, Inc. v. Latsis, 515 U.S. 347 (seaman test: duties and substantial connection prongs)
Harbor Tug & Barge Co. v. Papai, 520 U.S. 548 (mutual exclusivity of LHWCA and Jones Act)
S.W. Marine, Inc. v. Gizoni, 502 U.S. 81 (ship repairmen may or may not be seamen depending on connection)
Naquin v. Elevating Boats, L.L.C., 744 F.3d 927 (5th Cir.) (facts supporting seaman status for certain repair/operation duties)
Becker v. Tidewater, Inc., 335 F.3d 376 (5th Cir.) (requiring evidence of exposure to perils of the sea for seaman nature prong)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
In re Buchanan Marine, L.P., 874 F.3d 356 (2d Cir.) (workers confined to dockside barge repairs not seamen)