Seas Shipping Co. v. Sieracki - 328 U.S. 85, 66 S. Ct. 872 (1946)

Rule:

A shipowner's obligation of seaworthiness extends to longshoremen injured while doing the ship's work aboard but employed by an independent stevedoring contractor whom the owner has hired to load or unload the ship.

Facts:

Respondent Sieracki was employed by an independent stevedoring company which was under contract to petitioner shipowner to load its ship, the S. S. Robin Sherwood. Respondent was on the vessel loading cargo. The winch he operated was controlled by a ten-ton boom at number five hatch. While it was being put down the shackle supporting the boom broke at its crown, causing the boom and tackle to fall and injure respondent. Respondent sued petitioner and two other companies, i.e., the Bethlehem Steel Company, to which the Maritime Commission had awarded the contract for constructing the ship, and Bethlehem Sparrow's Point, Inc., which had built part of the ship under agreement with the steel company. The District Court found that the shackle had broken as the result of a defect which had occurred in its forging. The Bethlehem companies had purchased this equipment from another concern. Nevertheless, the court held they were negligent in not having tested it adequately before installing it. But the court considered petitioner to be under no such obligation to test and therefore not negligent. Accordingly, it gave judgment against the two Bethlehem companies but in favor of petitioner. The Circuit Court of Appeals reversed as to petitioner. Accepting the District Court’s conclusion that it was not negligent, the Court of Appeals was of the opinion that respondent should recover for the ship's lack of seaworthiness. A writ of certiorari was granted. 

Issue:

 Did the obligation of seaworthiness, traditionally owed by an owner of a ship to seamen, extend to a stevedore injured while working aboard the ship? 

Answer:

Yes.

Conclusion:

The Court affirmed the lower court's holding that the ship was unseaworthy and that the shipowner's obligation of seaworthiness extended to longshoremen injured while doing the ship's work aboard but employed by an independent stevedoring contractor whom the owner hired to load or unload the ship. The Court rejected the owner's argument that there was no obligation because there was no contract between the owner and the stevedore. The Court held that the duty was absolute and flowed from considerations regarding the hazards maritime service placed upon men who performed it, rather than any consensual or contractual basis of responsibility. The Court also held that the stevedore's recovery was not barred by the Longshoremen's and Harbor Workers' Compensation Act, 33 U.S.C.S. § 901 et seq., because it only created an exclusive remedy against the stevedore's employer and, therefore, did not apply to the shipowner.