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Rebstock v. Sonat Offshore Drilling

United States District Court, E.D. Louisiana
Apr 25, 1991
764 F. Supp. 75 (E.D. La. 1991)

Summary

holding that Jones Act seaman status has no relevance in allowing a seaman recovery under general maritime negligence law against a non-employer third party

Summary of this case from Scarborough v. Clemco Industries

Opinion

Civ. A. No. 90-3902.

April 25, 1991.

Robert A. McMahon, Jr., Bernard, Cassisa Law Firm, Metairie, La., for plaintiff Robert J. Rebstock, Sr.

Patricia A. Krebs and Richard J. Guidry, Nesser, King LeBlanc, New Orleans, La., for defendant Sonat Offshore Drilling, Inc. and defendant Amoco Production Co.


MEMORANDUM OPINION


Before the court is a motion filed by the defendants Sonat Offshore Drilling (Sonat) and Amoco Production Company (Amoco) to dismiss the claims of the plaintiff Louvinia Rebstock for loss of consortium, service, and society. After reviewing the motion, memoranda of counsel, the record, and the law, the court denies the motion.

Following the Supreme Court decision in Miles v. Apex, ___ U.S. ___, 111 S.Ct. 317, 112 L.Ed.2d 275 (1990), courts in this district have held that the spouse of a Jones Act seaman is not entitled to damages for loss of consortium under the general maritime law of unseaworthiness. See Breland v. Western Oceanic, Inc., 755 F. Supp. 718 (W.D. 1991); Anglada v. Tidewater, Inc., 752 F. Supp. 722 (E.D.La. 1990); Turley v. Co-Mar Offshore Marine Corp., No. 90-2497, 1991 WL 42564 (E.D.La. March 21, 1991); McGee v. Bean Dredging Corp., No. 90-0394 (E.D.La. March 8, 1991); Lacroix v. Exploration Employment Service, Inc., No. 90-0985 (E.D.La. February 6, 1991).

All of the above cases involved a Jones Act claim by the injured seaman against the seaman's employer combined with claims for unseaworthiness under the general maritime law.

A Jones Act seaman's recovery for negligence against his employer is limited to a recovery under the Jones Act; the seaman cannot assert a general maritime law negligence claim against his employer. However, the seaman may assert a general maritime law unseaworthiness claim against his employer. Under the Jones Act, the seaman may recover only for pecuniary losses; loss of consortium is not provided for. The Court's holding was intended to insure that a Jones Act seaman asserting a claim under the Jones Act and the doctrine of unseaworthiness against his employer did not recover more than Congress intended when it established the Jones Act. The Supreme Court stated in Miles v. Apex that it would not sanction more expansive remedies in a judicially created remedy than Congress provided for in the Jones Act. Miles, 111 S.Ct. at 325.

In the present case, the plaintiffs have not asserted a Jones Act claim. The plaintiffs have asserted a general maritime law negligence action against third parties. Mr. Rebstock's status as a Jones Act seaman has no relevence in connection with this suit. Recovery under the general maritime law of negligence is essentially the same as under the common law and loss of consortium damages are recoverable. The facts of the present case are similar to a Fifth Circuit case in which the spouse of a seaman who asserted a general maritime law negligence claim against a third party was allowed to recover damages for loss of consortium. Tullos v. Resource Drilling, Inc., 750 F.2d 380, 386 (5th Cir. 1985). Because Miles v. Apex and its progeny do not affect Tullos's holding on this issue, the court finds that Mrs. Rebstock should be allowed to pursue her claims against the defendants.

The uniformity sought by the Miles v. Apex Court is not affected by this court's ruling. Miles v. Apex sought to establish a uniform rule for seaman suing their employers. Seaman suing third parties were not considered by the Supreme Court. Indeed, to rule that the spouse of an injured seaman is not entitled to loss of consortium damages under the general maritime law of negligence would create an inconsistency between seamen and longshoremen. Under section 5(b) of the Longshore and Harbor Workers' Act, 33 U.S.C. §§ 901- 950, which permits a longshoreman to sue a nonemployer vessel owner for negligence, the spouse of the longshoreman is permitted to recover loss of consortium damages. See T. Schoenbaum, Admiralty and Maritime Law, section 6-10, at 221. Uniformity is best promoted by allowing a seaman to recover the same damages for negligence that a longshoreman may recover.

Accordingly,

IT IS ORDERED that the defendants' motion to dismiss the claims of Mrs. Rebstock be DENIED and the motion scheduled for APRIL 24, 1991 be CANCELED.


Summaries of

Rebstock v. Sonat Offshore Drilling

United States District Court, E.D. Louisiana
Apr 25, 1991
764 F. Supp. 75 (E.D. La. 1991)

holding that Jones Act seaman status has no relevance in allowing a seaman recovery under general maritime negligence law against a non-employer third party

Summary of this case from Scarborough v. Clemco Industries

holding that status as a Jones Act seaman has no relevance in allowing a seaman recovery for a general maritime law negligence action against third parties

Summary of this case from Stogner v. Central Boat Rentals, Inc.

holding that the spouse of a Jones Act seaman could recover nonpecuniary damages in a negligence action against a nonemployer third-party defendant

Summary of this case from Gerdes v. G H Towing Co.

In Rebstock, the court relied on a pre- Miles Fifth Circuit decision, Tullos v. Resource Drilling, Inc., 750 F.2d 380 (5th Cir. 1986), which was based on case law rejected by Miles.

Summary of this case from MASTRODONATO v. SEA MAR, INC.

In Rebstock, the spouse of a seaman asserted claims for loss of consortium, service, and society in a general maritime law negligence action against nonemployer third parties.

Summary of this case from Gerdes v. G H Towing Co.

In Rebstock, the District Court for the Eastern District of Louisiana, Judge Mentz, held that a seaman's wife could seek loss of consortium damages in a general maritime negligence action against a third party.

Summary of this case from Trident Marine, Inc. v. M/V Atticos

In Rebstock, Judge Mentz held that Miles sought to establish a uniform rule for seamen suing their employer, but that Miles left untouched the rights of a seaman's spouse to sue third parties for loss of consortium under the general maritime law.

Summary of this case from Ellender v. John E. Graham Co.

In Rebstock v. Sonat Offshore Drilling, 764 F. Supp. 75 (E.D.La. 1991), a Jones Act seaman, and his spouse, asserted negligence claims against a defendant, a third party who was not the plaintiff-seaman's employer, in relation to the plaintiff-seaman's injury. The defendant moved to dismiss the loss of consortium claim asserted against it by the plaintiff spouse.

Summary of this case from Mussa v. Cleveland Tankers

In Rebstock v. Sonat Offshore Drilling, 764 F. Supp. 75 (E.D.La. 1991), a Jones Act seaman, and his spouse, asserted negligence claims against a defendant... third party who was not the plaintiff-seaman's employer, in relation to the plaintiff-seaman's injury. The defendant moved to dismiss the loss of consortium claim asserted against it by the plaintiff spouse.

Summary of this case from Trahan v. Texaco, Inc.

In Rebstock, the district court held that loss of consortium damages are recoverable in a general maritime action against third parties, relying on Tullos v. Resource Drilling, Inc., 750 F.2d 380 (5th Cir. 1985).

Summary of this case from Trahan v. Texaco, Inc.

In Rebstock v. Sonat Offshore Drilling, 764 F. Supp. 75 (E.D.La. 1991), a Jones Act seaman, and his spouse, asserted negligence claims against a defendant... third party who was not the plaintiff-seaman's employer, in relation to the plaintiff-seaman's injury. The defendant moved to dismiss the loss of consortium claim asserted against it by the plaintiff spouse.

Summary of this case from Vedros v. Public Grain Elevator

In Rebstock, the district court relied upon Tullos v. Resource Drilling, Inc., 750 F.2d 380 (5th Cir. 1985) when it held that loss of consortium damages were recoverable in a general maritime law negligence action against third parties.

Summary of this case from Phillips v. Water Towing, Inc.
Case details for

Rebstock v. Sonat Offshore Drilling

Case Details

Full title:Robert J. REBSTOCK, Sr., et al. v. SONAT OFFSHORE DRILLING, et al

Court:United States District Court, E.D. Louisiana

Date published: Apr 25, 1991

Citations

764 F. Supp. 75 (E.D. La. 1991)
1991 A.M.C. 2183

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