Stewart v. Dutra Construction Co.

Background

A construction company owned the Super Scoop, a massive floating dredge used to dig a trench for Boston’s tunnel project. A marine engineer working on a scow alongside the dredge was seriously injured when the scow struck the dredge. He sued, claiming he was covered by maritime negligence laws and, alternatively, seeking recovery against the vessel owner under a federal workers’ compensation statute.

Reasoning

The Court considered whether a dredge like the Super Scoop counts as a “vessel” under the Longshore and Harbor Workers’ Compensation Act. It relied on a long-standing statutory definition that a vessel is any watercraft “used, or capable of being used, as a means of transportation on water.” The Court explained that a craft need not be primarily a transport ship or moving at the exact moment of injury to qualify. Because the Super Scoop carried crew and equipment over water and was practically capable of maritime transport, it met the vessel definition.

Real world impact

The ruling makes clear that dredges and similar floating construction platforms can be treated as vessels for federal maritime law. That means injured workers on those craft may be eligible to seek negligence recovery from vessel owners, and courts should evaluate vessel status based on practical capability, not a momentary snapshot. The case is sent back to lower courts for further proceedings consistent with this ruling.