## Facts

- Keith Coffin and other vessel-based tankermen worked aboard inland tank barges operated by Blessey Marine Services, Inc.
- The tankermen were assigned to specific vessels or fleets, lived aboard during hitches, and served as members of the vessel crews on inland-waterway voyages.
- Their work included overseeing loading and unloading of liquid cargo and monitoring cargo during transport.
- They also performed crew functions affecting safe operation and seaworthiness, including managing trim and stability, handling lines, and participating in navigation-related operations as part of the crew.
- The tankermen sued for overtime under the Fair Labor Standards Act (FLSA), claiming loading/unloading was “nonseaman” work that consumed a substantial portion of their time.
- Blessey argued the tankermen were “seamen” exempt from FLSA overtime because their duties, including cargo operations, aided the vessel’s transportation mission and seaworthiness.
- The district court denied Blessey’s summary-judgment motion, treating loading/unloading as categorically nonseaman work and setting trial on whether it constituted a “substantial” portion of the tankermen’s work.
- The district court certified an interlocutory appeal, and the Fifth Circuit accepted review.

## Issues

1. Whether vessel-based tankermen who perform cargo loading/unloading and other crew functions qualify as “seamen” exempt from FLSA overtime under 29 U.S.C. § 213(b)(6).
2. Whether cargo loading/unloading is categorically “nonseaman” work, or instead requires a functional inquiry tied to the vessel’s transportation function and the employee’s overall duties.
3. Whether the summary-judgment record showed any genuine dispute of material fact on the tankermen’s exempt seaman status.

## Decision

- The Fifth Circuit vacated the order denying summary judgment and remanded with instructions to enter judgment for Blessey.
- The court held the tankermen were FLSA-exempt “seamen.”
- The court ruled the district court misread circuit precedent by treating loading/unloading as nonseaman work as a matter of law.
- On the largely undisputed record, the tankermen’s cargo-related tasks were performed in their capacity as vessel crew and primarily aided the vessel’s operation as a means of water transportation.

## Legal Principles

- The FLSA exempts from overtime “any employee employed as a seaman.” 29 U.S.C. § 213(b)(6).
- Seaman status turns on whether the employee’s work is rendered primarily as an aid to the vessel’s operation as a means of transportation and whether the employee is more or less permanently attached to a vessel (or fleet) with duties contributing to the vessel’s function or mission.
- Task labels are not dispositive; the analysis considers the nature and character of the employee’s work taken as a whole.
- Loading and unloading are not per se nonseaman activities; when performed by vessel-based crew as part of the transportation mission and to maintain seaworthiness (including trim and stability), such work may qualify as seaman work.
- Summary judgment is proper where the record shows no genuine dispute that the employee performed only seaman work and therefore falls within the exemption.

## Conclusion

The Fifth Circuit held that vessel-based tankermen who load and unload cargo as part of their crew responsibilities, in a manner tied to the vessel’s transportation function and seaworthiness, are exempt “seamen” under the FLSA; loading/unloading requires a functional, context-specific analysis rather than a categorical rule.


Coffin v. Blessey Marine Servs., Inc., 771 F.3d 276 (5th Cir. 2014)