Chandris, Inc. v. Latsis

Summary

Justice O'Connor's majority opinion held that Jones Act seaman status requires duties contributing to a vessel's function or mission and a connection to a vessel in navigation, or an identifiable group of vessels, substantial in both duration and nature. The inquiry distinguishes sea-based employees from land-based workers and cannot turn solely on participation in a particular voyage. The Court affirmed the judgment ordering a new trial because the drydock instruction improperly removed the vessel's navigation status from the jury on the existing record and excluded potentially relevant evidence of Latsis' work during the conversion. It also declined to consider petitioners' Rule 51 argument because it was not presented in the certiorari petition. Justice Stevens, joined by Justices Thomas and Breyer, concurred in the judgment but argued that an employee contributing to a ship's mission during a voyage on the high seas is necessarily a seaman, without an additional substantial-connection inquiry.