Aguilar v. Standard Oil Co. of NJ

Background

These consolidated cases involve two seamen injured while leaving or returning from authorized shore leave. One was a messman on the Steamship Beauregard who, leaving the ship at Pier C in Philadelphia, fell into an unlit open ditch and was hurt. The other crewman was returning to the Steamship E. M. Clark via the only route across the Mexican Petroleum Company’s premises in Carteret, New Jersey, and was struck by a vehicle. Lower courts reached opposite results, producing a split among appeals courts that the Court agreed to resolve.

Reasoning

The Court asked whether a shipowner must provide “maintenance and cure” (basic medical care and living allowance) and wages when a seaman is hurt while on authorized shore leave but not working for the ship. The opinion explains that the duty to care for sick or injured seamen is an old, broad obligation implied in the employment relationship. Because shore leave is necessary to the ship’s business and crew welfare, injuries suffered on required routes to and from the ship fall within that protection so long as the seaman’s injury was not caused by willful misconduct. The Court stressed the duty does not depend on the shipowner’s negligence or control of third-party premises.

Real world impact

The Court affirmed the decision for the messman and reversed and remanded the other case for further proceedings consistent with this holding. The decision makes it easier for seamen injured on authorized shore leave along required routes to obtain employer-paid medical care and wages, and it can impose obligations on shipowners even when the injury occurs off the vessel on third-party property.

Dissents or concurrances

The Chief Justice would have affirmed the second case but concurred in the result for the first on treaty grounds; Justice Roberts did not participate.