## Facts

- William G. Bridges, a Penrod Drilling Company roustabout and Jones Act seaman assigned to the submersible rig PENROD 72, was injured while unloading equipment from the supply vessel M/V THOMAS DRAYTON, operated by Offshore Logistics Services, Inc.
- In severe weather (rough seas and high winds), several 55-gallon drums on the vessel had broken free and were rolling on deck.
- Bridges was ordered by Penrod supervisors to board the supply vessel to retrieve/unload needed equipment despite the visible hazard.
- After boarding, Bridges was crushed between a loose drum and other heavy equipment and sustained serious injuries.
- Bridges sued Penrod under the Jones Act and general maritime law, and sued Offshore under general maritime law.
- The personal-injury claims settled; remaining disputes concerned indemnity/contribution and allocation of fault between Penrod and Offshore.
- The district court denied indemnity between the defendants and apportioned fault two-thirds to Penrod and one-third to Offshore.

## Issues

1. Whether a Jones Act seaman performing cargo-handling tasks can be treated as a Sieracki seaman for purposes of liability and indemnity doctrines.
2. Whether Offshore was entitled to indemnity from Penrod under LHWCA-related or Sieracki/Yaka-type theories.
3. Whether the district court clearly erred by allocating fault two-thirds to Penrod and one-third to Offshore.

## Decision

- The Fifth Circuit affirmed.
- Bridges remained a Jones Act seaman; performing longshore-type work did not convert him into a Sieracki seaman.
- Offshore had no right to indemnity from Penrod on the LHWCA/Sieracki theories asserted.
- The two-thirds/one-third comparative-fault allocation was not clearly erroneous.

## Legal Principles

- A worker’s Jones Act seaman status is not reclassified on a task-by-task basis; temporary cargo-handling does not create Sieracki seaman status.
- LHWCA-based indemnity concepts tied to longshore/harbor-worker status do not apply where the injured worker is a Jones Act seaman and the asserted statutory framework is inapplicable.
- In the absence of an applicable statutory or contractual indemnity right, liability between maritime tortfeasors is allocated under comparative fault, and appellate review of fault allocation is deferential (clear-error review).

## Conclusion

The court held that a Jones Act seaman ordered into an obvious deck-cargo hazard does not gain Sieracki status, rejected LHWCA-driven indemnity reallocation between the defendants, and upheld the district court’s comparative-fault apportionment of two-thirds to the employer/rig operator and one-third to the supply-vessel operator.


Bridges v. Penrod Drilling Co., 740 F.2d 361 (5th Cir. 1984)