Supreme Court of the United States
Stewart v. Dutra Construction Co.
February 22, 2005543 U.S. 481
Summary
Justice Thomas delivered the unanimous opinion of the eight participating Justices. The Court held that 1 U. S. C. § 3 supplies the definition of “vessel” throughout the Longshore and Harbor Workers’ Compensation Act, including its exclusion of seamen and its vessel-negligence provision. A watercraft qualifies if it is practically capable of maritime transportation, regardless of its primary purpose or whether it is moving when an injury occurs. The Super Scoop dredge therefore qualified as a vessel. The Court reversed the Court of Appeals and remanded without deciding whether Stewart satisfied the remaining requirements for seaman status. There were no separate opinions; Chief Justice Rehnquist did not participate.
Holding
- The statutory definition governing vessel status under the LHWCA.. The definition in 1 U. S. C. § 3 governs “vessel” throughout the LHWCA, including §§ 902(3)(G) and 905(b), and informs the corresponding determination of Jones Act seaman status.
- Whether primary purpose or actual movement determines vessel status.. A watercraft is a vessel when it is practically capable of maritime transportation, regardless of its primary purpose or its state of transit at a particular moment.
- Whether the Super Scoop qualified as a vessel.. The Super Scoop was a vessel under § 3 and the LHWCA.
Docket 03-814
Cited authorities
- Pub. L. 98-426, 33
- 38 Stat. 1185
- 41 Stat. 1007
- 96 Stat. 1955
- 33 U.S.C. § 905
- 33 U.S.C. § 905
- 33 U.S.C. §902
- 1 U.S.C. § 3
Cited by
- Michael Polak v. Riverside Marine Construction, Inc.
- Gilbert Sanchez v. Enterprise Offshore Drilling LLC and Smart Fabricators of Texas, LLC
- Gates v. American Bridge Company
- Fieldwood Energy LLC and the Official Committee of Unsecured Creditors
- QuarterNorth Energy LLC and certain of its affilia v. Atlantic Maritime Services LLC
- Willard Stewart, Plaintiff, Appellant v. Dutra Construction Company, Inc., Defendant, Appellee
- Skipper Marine of Madison, Inc. v. 2019 Vr5 Bayliner, Id 014883 Bl0449, Hull Blbx2536j819
- Griffin v. Specialized Environmental Services Inc