Background:
The plaintiff, Illi Samson ("Samson"), appealed the district court's granting of summary judgment in favor of American Seafoods Co. ("American"). The district court held that, there were no genuine issues of material fact whether by requiring Samson to work 16 hour work days for months at a time, that American was negligent or created an unseaworthy condition leading to Samson's injuries.

American was aware that it required 16-hour shifts, with no days off, for months at a time on Samson's boat, the F/T American Triumph. Another employee, Alan Davis, stated that other boats use 12 and 14-hour shifts and that the company, American, was experiencing with shorter shifts to see if those shifts were better for the seaman.

 Davis also testified that the 16-hour shifts were shocking to him when he first entered the industry standard. However, Davis grew to accept this as the industry standard.

Samson fell during the final hour of the 16-hour shift and had previously complained to American Seafoods that his shift was too long and caused him to be exhausted. Samson's job involved lifting and flipping 70 lb trays of frozen fish.

At the time of his injury, Samson tried to shift his weight when his legs gave out under him as the boat rolled.

Samson filed this action under Jones Act negligence, and unseaworthiness. American moved for summary judgment and the district court granted it. Samson appealed to this Court.

Issue:                                                                                                                                           
Did this Court find that Ili presented issues of material fact whether requiring Ili to work 16-hour shifts, months on end, was negligent and that the negligence caused Ili's injury?

Held:
There was no dispute that Samson was a seaman and that American owed him a duty to provide a safe work environment under the Jones Act. Therefore, American owed Samson a duty to provide a reasonably safe workplace for Samson.

Moreover, this Court found that a reasonable jury could have concluded that requiring Samson to work a 16-hour shift was a breach of American's duty to provide a reasonably safe work environment. This Court relied on Davis's deposition in which he stated that American used shorter shifts on other boats in an experiment to see if those shifts are better for the seamen. Accordingly this Court found, Samson created genuine issues of material fact as to whether American was negligent by failing to act resonably, under the circumstances. in providing a safe place to work.

This Court also found that Samson established sufficient causation to survive summary judgment on the Jones Act claim. The Court noted that the Jones Act claim standard for causation only requires that the employer's negligence be a cause, however slight, of the injury.

This Court held that the length of the shift and Samson's duties, including flipping 70 lb trays of frozen fish, created a genuine issue of material fact whether the length of his shift played any role, however slight, in causing his fall and subsequent injury.

Also, the Court considered Samson's unseaworthiness claim. Both parties conceded and it is undisputed that Samson is a seaman and thus, entitled to a warranty of seaworthiness. This Court noted that lack of adequate crew is a basis for unseaworthiness and that requiring a crew to work 16-hour shifts for months on end could indicate that the ship is not adequately manned with crew to perform its duties in a seaworthy manner.

Finally, the Court considered whether requiring the crew to work 16-hour shifts every day was a substantial factor in causing Samson's injury. This standard requires a showing of a higher degree of causation than a Jones Act negligence claim.

This Court recognized that the same evidence supporting Samson's Jones Act claim also supports his unseaworthiness claim, and rather than parsing and affirming/denying the district court's ruling in parts, this Court reversed and remanded Samson's claim for a jury to determine.

Ultimately this Court reversed the granting of summary judgment.

Comment:
In bringing a Jones Act claim for neglgience, the plaintiff must establish first, that their employer failed to act in a reasonably prudent manner, much like under common law negligence,  and thus breached their duty to provide a safe work environment.  

Once the plaintiff is able to establish the employer's negligence, they then move onto causation. The plaintiff need to only show that the employer's negligence, was a cause, however slight, in causing his/her injury. This is known as a "featherweight" standard of causation under Jones Act negligence claims.

The plaintiff has a higher burden to show that the employer was negligent but a featherweight burden in showing that the negligence played a role in causing the injury.

Steve Gordon