Michael Williams v. C&G Boats, Inc. et al.

Summary

The United States District Court for the Eastern District of Louisiana converted defendants’ unopposed Rule 12(c) motion for judgment on the pleadings into a motion for summary judgment because defendants submitted materials outside the pleadings. The court held that the undisputed record did not establish plaintiff’s status as a seaman or otherwise support an unseaworthiness claim, and dismissed those claims with prejudice.

Holdings

1. A court may convert a Rule 12(c) motion into a Rule 56 motion when matters outside the pleadings are presented and not excluded, provided the nonmoving party had adequate notice and at least ten days to submit evidence.
2. Summary judgment is appropriate when the movant shows that no genuine dispute as to any material fact exists and that the movant is entitled to judgment as a matter of law; an unopposed motion may be granted only when it satisfies that standard.
3. Only seamen, or persons qualifying under the applicable seaman-status doctrine, may bring an unseaworthiness claim against a vessel owner; the undisputed record showed that Williams was not entitled to assert such a claim.

Questions Presented

1. Whether the defendants' Rule 12(c) motion should be converted to a motion for summary judgment because defendants submitted materials outside the pleadings and plaintiff had adequate notice and time to respond.
2. Whether the undisputed record established that Williams was not a seaman entitled to assert an unseaworthiness claim under general maritime law.
3. Whether defendants were entitled to summary judgment on and dismissal with prejudice of Williams's unseaworthiness claims.

Disposition

dismissed