Justia Admiralty & Maritime Law Opinion Summaries

Brian Ranger, a maintenance worker for Alamitos Bay Yacht Club, was injured while performing his duties, which included hoisting and mooring vessels. On August 28, 2018, he slipped and fell while boarding a vessel, resulting in serious injuries. Ranger applied for state workers' compensation and subsequently sued the Club under general maritime law, alleging negligence and unseaworthiness.The Los Angeles County Superior Court sustained the Club's demurrer without leave to amend, concluding that Ranger failed to allege facts implicating federal admiralty jurisdiction. Although the court acknowledged the tort occurred on navigable waters, it found that Ranger did not demonstrate his fall posed more than a fanciful risk to maritime commerce. The Court of Appeal affirmed the decision but on different grounds, holding that the Longshore and Harbor Workers’ Compensation Act (LHWCA) displaced general maritime law, making California’s workers’ compensation scheme Ranger’s exclusive remedy.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that the 1984 amendments to the LHWCA, which exclude certain workers from federal workers' compensation if they are covered by state laws, did not abrogate general maritime remedies for those outside the LHWCA’s scope. The court also determined that California’s workers’ compensation exclusive-remedy provision could not deprive Ranger of his substantive federal maritime rights under the supremacy clause of the federal Constitution. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings to address unresolved issues, including whether Ranger’s claims properly invoked admiralty jurisdiction. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law