Jonathan Conner v. REC Marine Logistics, LLC

Summary

The United States District Court for the Eastern District of Louisiana granted in part and denied in part REC Marine Logistics, LLC’s motion for summary judgment in a Jones Act seaman’s action. The court held that REC Marine established the three elements of the McCorpen defense and therefore was not obligated to pay maintenance and cure, and it dismissed related punitive-damages claims. The court denied summary judgment on the remaining claims, including Jones Act negligence, unseaworthiness, and issues concerning the enforceability of a release.

Holdings

1. REC Marine established the McCorpen defense because Conner knowingly concealed or intentionally misrepresented a medical condition, the information was material to the hiring decision, and there was a causal link between the prior heart condition and the later heart attack. REC Marine was therefore absolved of its duty to pay maintenance and cure.
2. Conner could not recover punitive damages related to the dismissed maintenance-and-cure claim because REC Marine established the McCorpen defense and therefore had no duty to pay maintenance and cure.

Questions Presented

1. Whether REC Marine established all three elements of the McCorpen defense so as to bar Conner's maintenance-and-cure claims.
2. Whether Conner's alleged concealment of his prior heart attack, hospitalization, stent, and hypertension was intentional or knowing under the objective concealment standard.
3. Whether the undisclosed medical history was material to REC Marine's hiring decision.
4. Whether a causal link existed between Conner's prior heart condition and the later heart attack.
5. Whether Conner could recover punitive damages for REC Marine's failure to pay maintenance and cure after REC Marine established the McCorpen defense.

Disposition

other