Travis Franklin v. Seacor Marine, LLC

Summary

The United States District Court for the Western District of Louisiana considers Seacor Marine, LLC’s motion for summary judgment in Travis Franklin’s maritime injury action. The court holds that the L/B Robert was not a vessel in navigation when Franklin became ill during extensive repairs, so Franklin did not qualify as a Jones Act seaman and could not pursue Jones Act, unseaworthiness, or maintenance-and-cure claims. The ruling also addresses the exclusivity of the Longshore and Harbor Workers’ Compensation Act for claims against an employer.

Holdings

1. The L/B Robert was not a vessel in navigation when Franklin became ill. Its extensive repairs, year-long out-of-service period, substantial repair cost, transfer of repair control to shore-based contractors, and prolonged layup removed it from navigation.
2. The intended-purpose analysis is the proper test for determining when a vessel that has left navigation during repairs reenters navigation.
3. Because Franklin was not a Jones Act seaman, his Jones Act negligence, unseaworthiness, and maintenance-and-cure claims failed as a matter of law.
4. The LHWCA's exclusivity provision barred Franklin's negligence claims against Seacor under Louisiana law and general maritime law, and Franklin could not proceed under 33 U.S.C. § 905(b) because Seacor was his employer and operator, not the vessel owner.

Questions Presented

1. Whether the L/B Robert was a vessel in navigation when Franklin became ill, such that Franklin qualified as a Jones Act seaman.
2. Whether the L/B Robert had reentered navigation during repairs under a capable-of-navigation or intended-purpose test.
3. Whether Franklin could maintain claims for Jones Act negligence, unseaworthiness, and maintenance and cure if he was not a seaman.
4. Whether Franklin could pursue negligence claims against his employer under 33 U.S.C. § 905(b), Louisiana law, or general maritime law despite the LHWCA's exclusivity provision.

Disposition

other