Braen v. Pfeifer Oil Transportation Co.

Background

A mate (a ship’s officer) employed on an oil-transport company’s barge was ordered to lay decking on a raft at the company’s repair yard. The raft lay between a work lighter and the dock and the mate was standing on a catwalk preparing to board when the catwalk gave way and he was injured. A jury found for the mate, but the Court of Appeals reversed and dismissed his Jones Act claim, prompting Supreme Court review.

Reasoning

The key question was whether the mate was injured “in the course of his employment” under the Jones Act when the injury happened off the vessel. The majority relied on earlier decisions that Jones Act protection is not limited to injuries on navigable waters and treated being ordered to perform employer work as sufficient. Because the mate had seaman status and was carrying out his employer’s orders at the moment of injury, the Court held he was acting in the course of his employment and could recover under the Jones Act, reversing the Court of Appeals and reinstating the trial court judgment.

Real world impact

The decision means seamen who are sent ashore or to ship repair facilities to perform employer-ordered tasks can qualify for Jones Act recovery when negligence causes injury. Employers in marine repair yards and vessel crews are affected because off-vessel work ordered by a shipowner can be protected.

Dissents or concurrances

Justice Harlan (joined by Justices Frankfurter and Whittaker) agreed the appeals court erred but disagreed with reinstating judgment. He argued the character of the work matters; injuries must arise from duties related to the vessel before Jones Act liability applies.