## Facts

- William W. Evans was a compulsory river pilot licensed by the U.S. Coast Guard and the State of Delaware to pilot vessels through specified waters.
- United Arab Shipping Co. S.A.G. owned the M/V AL WATTYAH, which Evans piloted from Delaware waters to Maryland.
- After the vessel docked in Maryland, Evans attempted to disembark using a gangway arrangement that required stepping from the vessel to a vertical steel ladder on the pier and then to the dock.
- Evans fell during disembarkation and alleged injuries, including aggravation of a pre-existing neurological condition.
- Evans sued the vessel owner asserting (1) Jones Act negligence on the theory he was a seaman employee of the owner and (2) general maritime law claims (including negligence and unseaworthiness) based on the allegedly unsafe means of disembarkation.
- After a bench trial, the district court found the vessel owner negligent and found causation under the Jones Act’s relaxed (“featherweight”) causation standard, awarding damages.

## Issues

1. Whether a compulsory river pilot has an employer–employee relationship with the vessel owner sufficient to qualify as a “seaman” bringing a Jones Act negligence claim against that owner.
2. Whether, absent Jones Act status, a court may apply the Jones Act’s “featherweight” causation standard to general maritime law claims, including alleged aggravation of a pre-existing condition.

## Decision

- The Third Circuit reversed the determination that Evans was a Jones Act seaman employed by the vessel owner.
- The court held that a compulsory pilot, engaged by operation of pilotage requirements and licensing regimes, lacked the requisite employment relationship with the vessel owner for Jones Act coverage.
- The court vacated the causation and damages determinations to the extent they depended on the Jones Act’s relaxed causation standard.
- The case was remanded for reconsideration of causation and damages under traditional maritime proximate-cause principles applicable to general maritime law claims.

## Legal Principles

- Jones Act negligence requires an employer–employee relationship between the plaintiff seaman and the defendant.
- A compulsory river pilot, temporarily aboard pursuant to compulsory pilotage arrangements and exercising professional judgment under regulatory obligations, is not ordinarily an employee of the vessel owner for Jones Act purposes.
- The Jones Act “featherweight” causation standard is confined to Jones Act (and analogous statutory) claims and cannot be imported into general maritime law negligence or unseaworthiness actions.
- In general maritime law personal-injury claims, including claims involving aggravation of a pre-existing condition, liability requires proof of legal/proximate causation under traditional maritime tort principles.

## Conclusion

The Third Circuit held that a compulsory river pilot is not a Jones Act employee of the vessel owner and directed that any recovery proceed, if at all, under general maritime law using traditional proximate-cause analysis rather than the Jones Act’s relaxed causation standard.


Evans v. United Arab Shipping Co. S.A.G., 4 F.3d 207 (3d Cir. 1993)