Swanson v. Marra Brothers, Inc.
Headline: Court affirms that a longshoreman struck by a falling life raft on a pier cannot sue under the Jones Act, leaving non-seamen to seek state compensation or remedies instead.
Holding:
- Bars non-seamen injured on shore from suing under the Jones Act.
- Leaves such workers to pursue state-law claims or local compensation remedies.
- Keeps Jones Act protections focused on seamen and crew members.
Summary
Background
A longshoreman employed by a stevedoring company was injured on a Philadelphia pier when a life raft fell from a vessel and struck him. He first received benefits under Pennsylvania employers’ liability law, then filed a federal suit claiming the Jones Act allowed him to recover damages from his employer. A district court dismissed the suit as barred for a person not a seaman injured on shore; the Third Circuit affirmed, and the Supreme Court agreed to decide the matter.
Reasoning
The Court explained that the Jones Act gives a right to sue mainly to seamen injured in the course of their maritime employment. Earlier cases had allowed similar recoveries for stevedores working on a vessel in navigable waters, but Congress later passed the Longshoremen’s and Harbor Workers’ Compensation Act. That 1927 Act provides a compensation remedy for non-seamen injured on navigable waters and makes that remedy exclusive, while its terms do not extend federal employer liability for injuries that occur on shore. Because Congress restricted federal remedies for non-seamen and preserved Jones Act recovery for bona fide members of a vessel’s crew, the Court would not extend Jones Act suits to this non-seaman injured on land.
Real world impact
The ruling leaves non-seamen hurt on shore without a Jones Act claim and sends them to state-law remedies or to the compensation system Congress created for injuries on navigable waters. It keeps federal Jones Act protections focused on seamen and crew members.
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