Standard Oil Co. v. Anderson

Background

The injured person was a longshoreman working for a stevedore hired to load the ship Susquehanna with oil. The dock owner provided the steam winch, drum, and the winch operator, while the stevedore furnished the tackle, ropes, and most of the loading crew. The winch and drum sat on the dock about fifty feet from the hatch and the winchman necessarily relied on signals from a stevedore gangman on the ship. The jury found the longshoreman exercised due care and that the winchman negligently lowered the load and caused the injury.

Reasoning

The central question was whose employee the winch operator was while doing the hoisting. The Court looked to who hired, paid, and could discharge the winchman, who owned the winch and supplied the power, and who actually controlled the work. The dock owner had employed, paid, and retained the power to fire the winchman and charged the stevedore a set amount for the hoisting service. The Court treated the stevedore’s timing signals as cooperative information rather than authoritative control. Applying long-established rules about when a worker is doing the master’s work, the Court concluded the winch operator remained the dock owner’s employee and that the dock owner was therefore responsible for the operator’s negligence.

Real world impact

The decision means dock owners who furnish and operate hoisting machinery and employ the operators can be held responsible for related accidents. It clarifies that a stevedore’s timing signals do not by themselves transfer employer responsibility. The judgment of the lower courts was affirmed, resolving the dispute presented to the Court.