O'Donnell v. Great Lakes Dredge & Dock Co.

Background

A deckhand working on a ship that carried sand across Lake Michigan was sent ashore to help fix a gasket connecting the ship’s discharge pipe to a land pipe. While repairing the connection, a co-worker’s negligence let a heavy counterweight fall and injure the deckhand. The trial court denied the seaman’s Jones Act negligence claim but awarded wages; the Court of Appeals allowed maintenance and cure but held the Jones Act did not cover injuries that happen on land.

Reasoning

The Court examined whether the Jones Act’s promise that a seaman injured “in the course of his employment” allows recovery when the injury happens ashore. The opinion explains that Congress intended the Act to extend longstanding maritime protections and to incorporate the workplace-injury principles of the railroad law, so long as the subject is traditionally maritime. The Court stressed that admiralty law has long cared for seamen’s welfare—maintenance and cure applied whether injury occurred at sea or on land—and concluded the Jones Act similarly covers seamen injured while serving their vessel even if the accident occurs ashore. Relying on Congress’s power over commerce and maritime jurisdiction, the Court reversed the lower court’s limitation.

Real world impact

The decision lets seamen injured while working for their ship pursue negligence claims against their employer under the Jones Act even for ashore accidents, increasing potential employer liability and insurance exposure. The Court did not decide whether longshoremen or other temporary cargo workers ashore can recover in similar circumstances, leaving that question open for future cases.