Chandris, Inc. v. Latsis

Background

Antonios Latsis was a supervising engineer for a cruise-line company who worked on its fleet and sometimes from shore. On a voyage aboard the S.S. Galileo he developed a serious eye injury; the ship's doctor delayed proper care and Latsis lost most vision in his right eye. The ship later entered a six-month drydock renovation in Germany. Latsis sued under the Jones Act claiming the ship’s medical negligence, but the trial jury found he was not a seaman and the court excluded the drydock period from consideration.

Reasoning

The Court clarified what a worker must show to be a seaman. It held that the worker’s duties must contribute to the vessel’s function or mission, and that the worker must have a substantial connection to a vessel or identifiable fleet in both duration and nature. The Court rejected a rule that simply treats anyone on a voyage as automatically a seaman, but said that temporal and activity factors must be weighed together. As a rule of thumb, spending under about thirty percent of one’s work time aboard a vessel is normally inadequate, though exceptions are possible. The Court also said the drydock question is usually for the jury.

Real world impact

The decision sends the case back for a new trial and changes how juries and employers decide seaman status. Maritime workers who spend regular, continuous time aboard ships are more likely to qualify; occasional or mostly shore-based workers are less likely. The ruling is fact-driven and could change with reassignment, voyages, or different time records.

Dissents or concurrances

Justice Stevens, joined by Justices Thomas and Breyer, agreed with sending the case back but argued that any worker injured aboard a ship at sea should always be a seaman for the Jones Act.