Ingram Barge v. Ratcliff, No. 22-30577 (5th Cir. 2023)
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Appellant worked as a barge cleaner for T.T. Barge Services, which provides barge cleaning services to Ingram Barge Company. Appellant asserted negligence claims against Ingram after Appellant was injured by caustic soda that he was cleaning up on Ingram Barge 976, which was moored to one of T.T.’s work barges at the time of his injury. After Ingram filed a district court complaint to limit liability, Appellant counterclaimed and asserted claims of negligence against Ingram. T.T. also filed a claim for contribution and indemnity against Ingram. The district court granted summary judgment (1) as to Appellant’s lack of seaman status under the Jones Act and (2) as to all of Appellant’s negligence claims against Ingram. The district court then dismissed the case with prejudice. Appellant challenged the district court’s orders.
The Fifth Circuit affirmed. The court explained that T.T.’s Cleaning Barge is semi-permanently and indefinitely attached to land by steel cables, except for rare moves during repairs or to accommodate nearby dredging operations. Therefore, the district court did not err in finding that T.T.’s Cleaning Barge lacked vessel status at summary judgment.
Further, the court explained that to qualify as a Jones Act seaman, a plaintiff must satisfy two requirements. First, an employee’s duties must ‘contribute to the function of the vessel or to the accomplishment of its mission. Second, that employee must have a connection to a vessel in navigation that is substantial in terms of both its duration and its nature. Here, Ratcliff lacks a substantial connection to Ingram’s barges.
This opinion or order relates to an opinion or order originally issued on September 19, 2023.
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