unseaworthiness claim (Texas) · Go Syfert
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unseaworthiness claim in Texas

19 Texas opinions name it 2 courts 1959–2023 2 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Barry Brister and Karen Brister, Cross-Appellees v. A.W.I., Inc., Cross-Appellantsgreen
ca5 · 1991 · cited in 2 Texas opinions naming this issue, 2007–2022
2 sentences

2022See Rigdon Marine Corp. v. Roberts, 270 S.W.3d 220, 227 (Tex. App.—Texarkana 2008, pet. denied); see also Brister v. A.W.I., Inc., 946 F.2d 350, 355 (5th Cir. 1991) (“A shipowner has an absolute nondelegable duty to provide a seaworthy vessel.”).

2007The charge also properly informed the jury that the causation burden for the Jones Act claim was “legal cause” while the causation burden for the unseaworthiness claim was “proximate cause.” See Brister, 946 F.2d at 354-55 (contrasting liberal causation standard under Jones Act with more demanding proximate causation standard for unseaworthiness claim).

22
Yamaha Motor Corp., USA v. Calhoungreen
scotus · 1996 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006See Yamaha, 516 U.S. at 211 , 116 S.Ct. 619 .

2006See Yamaha, 516 U.S. at 211 , 116 S.Ct. 619 .

22
Chandris, Inc. v. Latsisgreen
scotus · 1995 · cited in 2 Texas opinions naming this issue, 2012–2023
2 sentences

2023See Chandris, Inc. v. Latsis, 515 U.S. 347, 354 (1995).

2012Id.

12
Bradford McPhillamy v. Brown & Root, Inc.green
ca5 · 1987 · cited in 2 Texas opinions naming this issue, 1987–1990
2 sentences

1990When a recovery is based on both a Jones Act claim and an unseaworthiness claim, the plaintiff is not entitled to any prejudgment interest "unless the jury apportions the damages between the Jones Act claim and the unseaworthiness claim." McPhillamy v. Brown & Root, Inc., 810 F.2d 529, 531-32 (5th Cir.1987).

1990When a recovery is based on both a Jones Act claim and an unseaworthiness claim, the plaintiff is not entitled to any prejudgment interest “unless the jury apportions the damages between the Jones Act claim and the unseaworthiness claim.” McPhillamy v. Brown & Root, Inc., 810 F.2d 529, 531-32 (5th Cir.1987).

12
Rigdon Marine Corp. v. Robertsgreen
texapp · 2008 · cited in 1 Texas opinions naming this issue, 2022–2022
1 sentence

2022See Rigdon Marine Corp. v. Roberts, 270 S.W.3d 220, 227 (Tex. App.—Texarkana 2008, pet. denied); see also Brister v. A.W.I., Inc., 946 F.2d 350, 355 (5th Cir. 1991) (“A shipowner has an absolute nondelegable duty to provide a seaworthy vessel.”).

11
Offshore Pipelines, Inc. v. Schooleygreen
texapp · 1999 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See id. (“Because the defendant’s duty to provide a seaworthy vessel is completely independent of its duty to exercise reasonable care, the plaintiff does not have to prove the defendant was negligent.”).

11
Seas Shipping Co. v. Sierackired
scotus · 1946 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See, e.g., Seas Shipping Co. v. Sieracki, 328 U.S. 85 (1946).

11
Martino Lieggi v. Maritime Company of the Philippines, \M/v Philippine Rizalgreen
· 1981 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014Co. of Phil., 667 F.2d 324, 326 (2nd Cir. 1981).

11
Sloan v. United Statesgreen
paed · 2009 · cited in 1 Texas opinions naming this issue, 2012–2012
1 sentence

2012See Sloan v. United States, 603 F.Supp.2d 798, 811 (E.D.Pa.2009) (evaluating, in suit brought under PVA and SAA against United States as vessel owner, seaman’s unseaworthiness claims arising from assault and emotional abuse by fellow crewman onboard vessel); see also Len v. American Overseas Marine Corp., 171 Fed.App’x. 489, 492 n. 2 (5th Cir.2006) (recognizing that SAA provides remedy against United States as vessel owner for seaman’s claim of retaliatory discharge by vessel operator).

11
Johnny C. Colburn, Cross-Appellant v. Bunge Towing, Inc., and M/v Terry K, Cross-Appelleesgreen
ca5 · 1989 · cited in 1 Texas opinions naming this issue, 1994–1994
2 sentences

1994It has ruled that "When a damage award is based on a jury verdict finding both Jones Act negligence and unseaworthiness, without providing `any basis for determining which *797 portion of the damage award, if any, is attributable to unseaworthiness rather than Jones Act negligence, it is impermissible to award prejudgment interest.'" Colburn v. Bunge Towing, Inc., 883 F.2d 372, 378 (5th Cir. 1989).

1994It has ruled that “When a damage award is based on a jury verdict finding both Jones Act negligence and unseaworthiness, without providing ‘any basis for determining which portion of the damage award, if any, is attributable to unseaworthiness rather than Jones Act negligence, it is impermissible to award prejudgment interest.’” Colburn v. Bunge Towing, Inc., 883 F.2d 372, 378 (5th Cir.1989).

11
McAllister v. Magnolia Petroleum Co.green
texapp · 1956 · cited in 1 Texas opinions naming this issue, 1987–1987
1 sentence

1987See McAllister, 290 S.W.2d at 316 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
Reviea v. Marine Drilling Co. green
texapp · 1990
2 sentences

1994Downen, 846 S.W.2d at 509 ; Reviea, 800 S.W.2d at 255 .

1993Id.

21993–1994
Downen v. Texas Gulf Shrimp Co. green
texapp · 1993
1 sentence

1994Downen, 846 S.W.2d at 509 ; Reviea, 800 S.W.2d at 255 .

11994–1994
Miles v. Apex Marine Corp. green
scotus · 1990
2 sentences

1993The United States Supreme Court ultimately held that since “nonpecuniary” damages, such as those for loss of society, were not made available under the Jones Act, they should not be made available under general maritime law. 498 U.S. at 31-33 , 111 S.Ct. at 325-26 .

1993The United States Supreme Court ultimately held that since “nonpecuniary” damages, such as those for loss of society, were not made available under the Jones Act, they should not be made available under general maritime law. 498 U.S. at 31-33 , 111 S.Ct. at 325-26 .

11993–1993
Mitchell v. Trawler Racer, Inc. green
scotus · 1960
2 sentences

1990Mitchell, 362 U.S. at 548 , 80 S.Ct. at 932 ; Mahnich v. Southern S.S.

1990Mitchell, 362 U.S. at 548 , 80 S.Ct. at 932 ; Mahnich v. Southern S.S.

11990–1990
McAllister v. Magnolia Petroleum Co. green
scotus · 1958
2 sentences

1987Id. at 225 , 78 S.Ct. at 1204 .

1987Id. at 225 , 78 S.Ct. at 1204 .

11987–1987
Dallas Railway & Terminal Company v. Oehler green
tex · 1956
2 sentences

1981Dallas Railway and Terminal Co. v. Oehler, 156 Tex. 488 , 296 S.W.2d 757 (1956). *74 Appellant asserts that he is entitled to recover under the unseaworthiness doctrine even though the jury found he was not a seaman.

1981Dallas Railway and Terminal Co. v. Oehler, 156 Tex. 488 , 296 S.W.2d 757 (1956). *74 Appellant asserts that he is entitled to recover under the unseaworthiness doctrine even though the jury found he was not a seaman.

11981–1981
Mahnich v. Southern Steamship Co. green
scotus · 1944
2 sentences

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

11959–1959
Pope & Talbot, Inc. v. Hawn green
scotus · 1953
2 sentences

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

11959–1959
McDonald v. Dingwall Shipping Co. green
txsd · 1954
1 sentence

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

11959–1959
Daniels v. Pacific-Atlantic S. S. Co. green
nyed · 1954
1 sentence

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

11959–1959
Spero v. Steamship the Argodon green
vaed · 1957
1 sentence

1959In Daniels v. Pacific-Atlantic Steamship Co., D.C.E.D.N.Y.1954, 120 F. Supp. 96, 99 , the Court stated: “The weight of authority is that an injury caused by slipping on a spot of oil or other matter of a transitory nature in and of itself does not support a cause of action for damages for unseaworthiness.” See also McDonald v. Dingwall Shipping Company, D.C.S.D.Tex.1954, 135 F.Supp. 374, 376 , in which the Court stated: “The cases upon which the Libelant places principal reliance, Pope & Talbot, Inc., v. Hawn [ 346 U.S. 406 , 74 S.Ct. 202 , 98 L.Ed. 143 ], supra; Seas Shipping Co. v. Sieracki,

11959–1959

Statutes the citing opinions construe

USC § 46u.s.c.688 (4) USC § 45u.s.c.51 (3) USC § 45u.s.c.51-60 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

LA 35 (1967–2019) TX 19 (1959–2023) NY 9 (1947–2004) CA 6 (1965–2002) FL 5 (1979–2011) IL 4 (1980–1988) WA 4 (1979–2005) AK 3 (1974–1991) AL 3 (1992–1996) MI 3 (2021–2021) OR 2 (1968–1988) VA 2 (1994–2012) MD 2 (1961–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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