QCR Autumn 2020: Sanchez v. Smart Fabricators, LLC – The U.S. Fifth Circuit Court of Appeals Analyzes Jones Act Seaman Status

U.S. Fifth Circuit Court of Appeals finds an injured welder to be a Jones Act seaman after distinguishing the facts of the case from those of an earlier Fifth Circuit decision.

In the recent decision of Sanchez v. Smart Fabricators of Texas LLC, (5th Cir. August 14, 2020) the U.S. Fifth Circuit Court of Appeals addressed the contours of Jones Act seaman status in reviewing a decision of the U.S. District Court for the Southern District of Texas. The district court had held that a welder who was injured when he tripped over a pipe on the deck of a jacked-up offshore drilling rig was not a Jones Act seaman based on its application of the Supreme Court’s two-pronged seaman status test. The Fifth Circuit disagreed with the lower court and reversed its decision based on earlier decisions examining seaman status.¹

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¹The Fifth Circuit had previously issued a decision holding that Sanchez was not a Jones Act seaman, however that decision was withdrawn.