Sayles v. Woods Hole, Martha's Vineyard And Nantucket Steamship Authority, 1:13-cv-12969

Plaintiff Susan Sayles slipped and injured her ankle on August 9, 2013 while exiting the M/V Island Home ferry through a metal lift-deck door onto a hydraulically operated vehicle lift deck.
There was a raised interior threshold (1.5–2 inches) marked with yellow diagonal paint; a gap existed between the threshold and the lift deck edge (Steamship Authority measured ~3 inches; Sayles estimated ~6 inches).
Sayles crossed the doorway earlier without incident, bought food, then returned carrying the food, opened the door, stepped out, and her left foot fell into the gap; she testified she did not see the gap.
Two prior incidents (June and September 2013) recorded similar injuries where other women’s legs fell into the same gap; after the September incident the ship added a rubber piece to the ramp edge.
Steamship Authority had posted red “Watch Your Step” signs and painted yellow outlines near the threshold; it moved for summary judgment, and Sayles sought partial summary judgment on liability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the gap an "open and obvious" danger, negating a duty to warn?	Sayles: gap was not visible to an ordinary passenger; she and others did not see it, so duty to warn existed.	Steamship Authority: gap was open and obvious; no duty to warn of an obvious hazard.	Genuine factual dispute exists; court denies summary judgment for defendant.
Were the posted warnings adequate to satisfy the carrier's duty?	Sayles: general “Watch Your Step” signs and paint were insufficient to warn of this concealed gap.	Steamship Authority: signs and markings provided adequate warning.	Court finds factual dispute about adequacy of warnings; summary judgment inappropriate.
Was defendant’s breach (if any) the proximate cause of injury, or was Sayles’ conduct sole cause?	Sayles: even if partly negligent, any comparative fault reduces damages but does not bar recovery; carrier breach may be proximate cause.	Steamship Authority: Sayles’ inattention/own negligence was the proximate cause.	Court holds causation is for the factfinder; defendant not entitled to summary judgment on proximate cause.
Should the court grant plaintiff partial summary judgment on liability?	Sayles: evidence establishes carrier liability as a matter of law.	Steamship Authority: disputes of material fact exist.	Court denies plaintiff's request; record insufficient to decide adequacy of warning as a matter of law.

Napier v. F/V DEESIE, Inc., 454 F.3d 61 (1st Cir. 2006) (summary judgment standard in admiralty same as general federal practice)
Celotex Corp. v. Catrett, 477 U.S. 317 (Sup. Ct.) (burden on movant to show absence of evidence supporting nonmovant)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Sup. Ct.) (standard for genuine dispute of material fact)
Kermarec v. Compagnie Generale Transatlantique, 358 U.S. 625 (Sup. Ct.) (carrier owes passengers reasonable care)
Muratore v. M/S Scotia Prince, 845 F.2d 347 (1st Cir.) (maritime carrier duty of reasonable care to passengers)
Carey v. Bahama Cruise Lines, 864 F.2d 201 (1st Cir.) (contributory negligence in admiralty mitigates damages)
United States v. Reliable Transfer Co., 421 U.S. 397 (Sup. Ct.) (allocation of fault in maritime cases)
Chaparro v. Carnival Corp., 693 F.3d 1333 (11th Cir.) (elements of maritime negligence)
La Esperanza de P.R. Inc. v. Cia de P.R., 124 F.3d 10 (1st Cir.) (maritime negligence principles govern admiralty torts)