Stewart v. Dutra case brief summary

Stewart v. Dutra (US 2004), handout

 

The dredge was a floating platform used to remove silt from the ocean floor and dump the silt onto scows floating alongside, and the dredge navigated short distances by manipulating its anchors and cables. The dredge used its bucket to move the scow on which the engineer was working, which caused the scow to collide with the dredge causing the engineer's severe injuries. The lower court found that the dredge was not a vessel, and thus the owner was not the owner of a vessel for purposes of the LHWCA, since the dredge did not have the primary purpose of navigation and was not in transit when the collision occurred. The U.S. Supreme Court unanimously held, however, that the definition of a vessel set out in 1 U.S.C.S. § 3 applied under the LHWCA, and thus the dredge was a vessel since it was a watercraft practically capable of maritime transportation. The definition did not require that the dredge be used primarily for navigation nor was the dredge required to be in motion at the time of the collision to qualify as a vessel, and the dredge was in fact used to transport equipment and workers over water.

 

-Court has broad interpretation of what a vessel is, noting that § 3 requires only that a watercraft be used or capable of being used as means of transportation on water to qualify as a vessel.