Carlisle Packing Co. v. Sandanger

Background

A packing company owned and ran a motor boat used in navigable Alaskan waters. A crew member was badly burned when he poured fuel from a can labeled 'coal oil' onto a stove fire and ignited it; the can actually contained gasoline. The trip was expected to last six to eight hours. No life preservers had been placed on board, and the injured worker says his burns were worsened while others searched for a preserver. The state trial court instructed the jury under ordinary negligence rules.

Reasoning

The Court reviewed maritime law about unsafe ships and safety equipment. It said the jury should have been told that a vessel is unsafe (called "unseaworthy" in maritime law) if a can labeled for coal oil actually contained gasoline, or if required life preservers were not aboard, and that a crew member may recover for injuries directly caused by such unsafe conditions. The Court found the trial instruction was legally wrong but harmless here because the jury’s verdict showed it found either negligence, lack of life preservers, or both. The owner’s request to limit damages to the vessel’s value under § 4283 was rejected because that protection was not pleaded in the state court.

Real world impact

The decision affirms the damage award and makes clear that boat owners can be held responsible for unsafe conditions and missing safety gear even if a trial was framed only as negligence. Crew members injured by those unsafe conditions may recover damages. Vessel owners must raise any claim to limit liability by pleading it before trial.

Dissents or concurrances

Justice Clarke simply concurred in the result of affirmance.