Sanchez v. Smart Fabricators of Texas, LLC, No. 19-20506 (5th Cir. 2020)Annotate this Case
After plaintiff was injured when he tripped on a pipe welded to the deck of a jacked-up offshore drilling rig, he filed a negligence action against Smart Fabricators under the Jones Act. The district court denied plaintiff's motion to remand to state court, granting Smart Fabricator's motion for summary judgment.
The Fifth Circuit held that the district court did not err in holding that plaintiff was not a Jones Act seaman. The court affirmed the district court's reasoning in distinguishing Naquin v. Elevating Boats, LLC, a 2014 case in which the court considered the "substantial nature" component of the seaman test. In this case, plaintiff's duties are readily distinguishable from Naquin's because plaintiff worked on drilling rigs only "while they were jacked up on the sea floor, with the body of the rig out of the water and not subject to waves, tides, or other water movement." Furthermore, while Naquin's workplace remained subject to the vicissitudes of a navigable waterway, plaintiff's workplace was stable, flat, and well above the water. Moreover, plaintiff did not perform "tasks requiring operating or navigating the rigs." Rather, the court explained that plaintiff was a welder, and he was injured when he tripped on a pipe welded to the floor, a circumstance unrelated to any perils of the sea.