Maritime Law Case Brief: Stewart v. Dutra Construction Company

This case brief examines the maritime law case of Stewart v. Dutra Construction Company. The case involves Willard Stewart, who was injured while working on a dredge called "super scoop" owned by Dutra Construction. The central issues revolve around whether Stewart qualifies as a seaman under the Jones Act and whether the dredge is considered a vessel under the Longshore and Harbor Workers' Compensation Act (LHWCA). The procedural history includes Stewart suing Dutra for negligence and Dutra disputing Stewart's seaman status and the dredge's vessel status. The court addressed the definition of a "seaman" and a "vessel," ultimately ruling that, while a dredge can be considered a vessel under LHWCA, the "super scoop" in this instance was not acting as a vessel at the time of the accident, and therefore Stewart's status as a seaman was not established. The court emphasized the importance of the vessel's primary function and its navigational capabilities. The case provides key insights into maritime law, specifically the interpretation of "vessel" and the requirements for seaman status.

Running head: MARITIME LAW 1
Maritime law
Name:
Institutional Affiliation:

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Maritime law
Case Citation: Stewart v. Dutra Construction Company
Parties: Willard Stewart, Plaintiff
Dutra Construction Company,
Defendant
Facts: The respondent Dutra Company was employed by states of Massachusetts to help in
extension of a turnpike through a tunnel. Dutra owned the largest drench “super scoop” which
was to dig the trench by removing silt from the ocean bed and dumping into one of its scows.
Super scoop has ability to move is restricted and can only moves to places with the help of a
tugboat by controlling its anchor and cables (Bilová, 2016). When digging the Boston tunnel it
only moved 30-50 feet each few hours. Appellant Willard Stewart was recruited by Dutra to keep
check the mechanical system on the super scoop, on the day of the accident one of the scows had
an engine break down and Stewart was fixing wires on the scow. The scow went into collision
with the super scoop and as a result Stewart was seriously injured.
Procedural History; Stewart sued the company under the Jones act accusing them of
negligence yet he was a seaman and also under article 59b) of the Longshore And Harbor
Worker’s Compensation Act (LHWCA) which allows insured worker’s to take legal action
against ‘vessel” owner as a third party for an harm caused by the employer’s negligence.
Dutra also filed a suit arguing that Stewart was not a seaman under Jones act
claim; he also disputed that super scoop was not a vessel as stated under Jones act. The Circuit
granted Dutra a ruling as a matter of law since the super scoop main work was construction and
not navigation also at the time of the accident it was not moving.

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Issues:
Issue 1: If seaman is a crew member of the vessel under the maritime law?
Issue 2: if a dredge is a vessel under the LHWCA?
Holdings: Issue 1: No a “seaman” is not a crew member of the vessel under the maritime law.
Issue 2: Yes a dredge is a vessel under the LHWCA.
Reasoning
Issue 1: Although Jones Act does not define ‘seaman” when maritime law was regulated
it showed that seaman was a phrase with a definite meaning according to maritime law.
The LHWCA stated a compensation for sea workers based on land and not to a crew of
any vessel; the court explained the connection of a worker to a vessel to be considered its
crew member.
Issue 2: (a) The revised chapters of LHWCA described a vessel as any watercraft that
can be used as instrument of navigation, then dredges are vessels since in order to
function they carry tools and crew over water and because were “capable of navigation
in and upon the waters”.
(b) Cope v. Vallette Dry Dock Co., 119 U.S 625, and Evansville & Bowling
Green Packet Co. v. Chero Cola Bottling Co.,271 U.S 19, pointed out the definition of a
vessel because practically they were not for ferrying people or goods from one place to
another, but for a worker seeking ‘seaman” status under Jones Act, they must prove that
their work contributed to vessels performance (Buchstein, 2015).

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(c) The Court ruled that “super scoop’ is not a vessel since its main duty is
construction and not for navigation and that it was not in movement when the accident
occured. According to Buchstein maritime law defines vessel as a watercraft which can
be used for navigation but does not mean should be used mainly for that purpose.
Decision:
The court affirmed under DiGiovanni, it argued that in order for super scoop to do its
function which was construction it had to navigate also that since at the time of the
accident the scoop was not on transit then Stewart status as a seaman was not defined.
Comment
The court was able to clearly define term “vessel” as stated by LHWCA article 3
other than as defined by the maritime law.

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References
Buchstein, F. (2015). Admiralty and maritime law in the Supreme Court. Salem Press
Encyclopedia.
Case Briefs in Legal English Classes. Studies in Logic, Grammar And Rhetoric, Vol 45, Iss 1, Pp
7-20 (2016), (1), 7.