Case Studies Flashcards
Give examples of significant maritime tort cases involving personal injury
- McDermott International, Inc. v. Wilander (1991)
McDermott International, Inc. v. Wilander addressed the definition of a “seaman” under the Jones Act and clarified the eligibility for seamen to claim benefits for injuries sustained while working on a vessel.
Key Points:
Job Function: The case involved Leslie Wilander, a painter injured while working on a vessel owned by McDermott International. The key issue was whether his job functions qualified him as a seaman under the Jones Act.
Contribution to Vessel Function: The Supreme Court ruled that a worker does not need to aid in the vessel’s navigation to be considered a seaman. Instead, it is sufficient if the worker contributes to the vessel’s function or the accomplishment of its mission.
Rejection of Navigational Aid Requirement: The Court rejected the requirement that seamen must perform tasks related to navigation or transportation, broadening the scope of who can be considered a seaman under the Jones Act.
Outcome:
The Supreme Court ruled in favor of Wilander, confirming that his work as a painter, which contributed to the maintenance and function of the vessel, qualified him for seaman status under the Jones Act.
- Chandris, Inc. v. Latsis (1995)
Chandris, Inc. v. Latsis was a pivotal Supreme Court case that clarified the criteria for determining “seaman” status under the Jones Act. The case involved Christopher Latsis, a superintendent engineer who was injured while working on a vessel owned by Chandris, Inc. He sought damages under the Jones Act, which provides protection to seamen.
Key Points:
Seaman Status Test: The Court established a two-part test to determine if a worker qualifies as a seaman under the Jones Act:
Employment Contribution: The worker’s duties must contribute to the function of the vessel or the accomplishment of its mission.
Substantial Connection: The worker must have a connection to a vessel (or an identifiable group of vessels) in navigation that is substantial in terms of both its duration and its nature.
Clarification of “Substantial Connection”: The Court indicated that a seaman’s connection to a vessel should be significant in terms of the percentage of time spent aboard the vessel, generally at least 30% of their working time.
Outcome:
The Supreme Court ruled in favor of Latsis, confirming that he met the criteria for seaman status under the Jones Act based on his substantial connection to the vessel and the nature of his work.
Give an example of a maritime tort case involving limits of liability in BLs
Norfolk Southern Railway Co. v. James N. Kirby, Pty Ltd. (2004)
Summary:
This Supreme Court case addressed the applicability of maritime law to a multimodal transportation contract and the enforceability of liability limits in bills of lading.
Key Points:
Case Background: James N. Kirby, Pty Ltd., an Australian company, shipped machinery from Australia to Alabama using a multimodal transportation contract. The goods were damaged en route, and Kirby sought damages from Norfolk Southern Railway, which handled the final leg of the transport.
Maritime Law Applicability: The Supreme Court ruled that maritime law governs multimodal transportation contracts if the primary objective of the contract is to accomplish the transportation of goods by sea.
Liability Limits: The Court upheld the liability limits in the bills of lading, emphasizing the importance of uniformity in the application of maritime law to promote predictability in international shipping.
Outcome:
The Supreme Court held that the liability limits set forth in the ocean carrier’s bill of lading extended to Norfolk Southern, limiting the damages Kirby could recover.
Give an example of a maritime tort case regarding enviromental liability and punitive damages
Exxon Valdez Oil Spill (1989)
Summary:
The Exxon Valdez oil spill is one of the most significant environmental disasters in U.S. history, involving a massive oil spill off the coast of Alaska.
Key Points:
Incident Details: On March 24, 1989, the Exxon Valdez, an oil tanker, struck a reef in Prince William Sound, Alaska, spilling approximately 11 million gallons of crude oil.
Environmental Impact: The spill caused extensive environmental damage, affecting marine wildlife and ecosystems. It prompted significant public outcry and led to numerous legal and regulatory changes.
Litigation: The litigation included claims for environmental damage, economic losses to fishermen and local businesses, and punitive damages. In 2008, the U.S. Supreme Court reduced the punitive damages award from $2.5 billion to $507.5 million, emphasizing the need for proportionality between compensatory and punitive damages.
Outcome:
The case resulted in significant legal precedents regarding environmental liability and punitive damages, and it led to the passage of the Oil Pollution Act of 1990, which improved the federal government’s ability to respond to oil spills.
Give an example of a maritime tort case addressing issues of liability and compansation
In re: The Complaint of KIRBY INLAND MARINE, L.P., as Owner of the M/V MISS DOROTHY, for Exoneration from or Limitation of Liability (2020)
Summary:
This case involved a catastrophic barge explosion, addressing issues of liability and compensation under maritime law.
Key Points:
Incident Details: In 2020, the M/V MISS DOROTHY, owned by Kirby Inland Marine, was involved in a barge explosion on the Illinois River, resulting in fatalities and environmental damage.
Limitation of Liability: Kirby Inland Marine filed a complaint seeking exoneration from or limitation of liability under the Limitation of Liability Act of 1851, which allows vessel owners to limit their liability to the value of the vessel and its freight, provided they had no knowledge of the negligence causing the incident.
Claims: Multiple claims were filed, including those under the Jones Act, general maritime law, and for environmental damages.
Outcome:
The court proceedings focused on determining whether Kirby Inland Marine could limit its liability. The outcome of such cases often depends on whether the owner can prove a lack of privity or knowledge regarding the negligent acts that led to the incident. The case underscored the complexities of maritime liability and the interplay between various legal claims and statutes.
Give an example of a maritime court case involving DOHSA
Helman v. Alcoa Global Fasteners, Inc. (2011)
Summary:
Helman v. Alcoa Global Fasteners, Inc. is a case involving the Death on the High Seas Act (DOHSA) related to a maritime incident.
Key Points:
Incident Background: The case arose from a helicopter crash into the ocean near Santa Catalina Island, California, on January 13, 2008. The helicopter, operated by Alcoa Global Fasteners, was transporting personnel to an offshore drilling platform. The crash resulted in the deaths of the pilot and several passengers.
Legal Claims: The families of the deceased filed wrongful death lawsuits against Alcoa Global Fasteners under DOHSA, seeking compensation for the losses suffered due to the deaths that occurred over international waters.
Court Rulings:
District Court: The initial court had to determine whether DOHSA applied, given the location of the crash and the nature of the transportation. The court confirmed that DOHSA was applicable because the helicopter crash occurred over navigable waters beyond the three-mile territorial limit.
Appellate Court: On appeal, the court upheld the application of DOHSA. The court reiterated that DOHSA governs wrongful death cases on the high seas and that the plaintiffs were entitled to recover pecuniary damages only. This included financial support, lost wages, and other economic contributions that the deceased would have provided.
Damages and Limitations: The court emphasized that non-pecuniary damages, such as pain and suffering or loss of companionship, were not recoverable under DOHSA. The rulings were consistent with the act’s intention to provide a uniform and predictable legal framework for wrongful deaths occurring in maritime contexts.
Outcome:
The Helman v. Alcoa Global Fasteners, Inc. case reaffirmed the scope and limitations of DOHSA in maritime wrongful death claims. The court’s decision reinforced the principle that DOHSA restricts recovery to pecuniary losses, maintaining the act’s focus on financial compensation for the beneficiaries of the deceased. This case serves as a critical reference for DOHSA’s application in incidents involving vessels and maritime-related transportation.
