## Facts

- Gutierrez, a longshoreman, worked on unloading the S.S. Hastings at Ponce, Puerto Rico.
- The ship carried beans in broken and defective bags; some bags were being repaired during unloading.
- Beans spilled from the defective bags onto the dock during discharge.
- Gutierrez slipped on the spilled beans on the pier and suffered injuries.
- Gutierrez sued the shipowner, Waterman S.S. Corp., in admiralty alleging negligence and unseaworthiness based on the defective containers.
- The district court found the shipowner knew or should have known the defective bags would likely cause injury to workers near the unloading area and entered judgment for Gutierrez.
- The First Circuit reversed, reasoning the shipowner could not be negligent for events on a pier it did not control.

## Issues

1. Whether admiralty jurisdiction existed under the Extension of Admiralty Jurisdiction Act when the injury occurred on a pier during unloading but resulted from ship-related conduct.
2. Whether a shipowner may be liable in negligence for a dockside injury caused by foreseeable spillage from defective cargo containers, despite lack of control over the pier.
3. Whether defective cargo containers can constitute unseaworthiness, and whether the seaworthiness duty protects longshoremen injured on the pier while unloading.
4. Whether the claim was barred by laches because it was filed after the analogous local limitations period, absent prejudice to the shipowner.

## Decision

- The Supreme Court reversed the First Circuit and remanded.
- Admiralty jurisdiction existed because the alleged tort occurred while or before unloading and its shore impact was not remote in time or place from the wrongful act.
- The shipowner was liable in negligence for permitting unloading in defective bagging when it knew or should have known injury was likely; liability did not depend on control of the pier.
- The leaky bean bags were unfit and therefore rendered the vessel unseaworthy; the seaworthiness duty applied to longshoremen unloading whether on the ship or on the pier.
- Laches did not bar the suit because the district court’s finding of no prejudice from delay was not clearly erroneous.

## Legal Principles

- Maritime jurisdiction extends to ship-related torts whose wrongful conduct occurs on navigable waters even if the injury is consummated on land, when the shore impact is proximate in time and place.
- A shipowner’s negligence liability may attach for foreseeable dockside injuries caused by defective conditions created or permitted in connection with unloading operations, regardless of control over the accident location.
- Accepting cargo in faulty containers, or allowing containers to become faulty, can constitute unseaworthiness when the containers are unfit for their intended use and injure seamen or their substitutes.
- The warranty of seaworthiness protects longshoremen performing unloading work traditionally done by the crew, including when the injury occurs on the pier adjacent to the vessel.
- In admiralty, laches turns on unreasonable delay and prejudice; expiration of an analogous local limitations period is relevant but not dispositive.

## Conclusion

The Court held that maritime jurisdiction and shipowner liability may extend shoreward when a ship-related wrongful condition causes a near-in-time-and-place dockside injury, and it affirmed that defective cargo containers can create both negligence liability and unseaworthiness duties owed to longshoremen unloading the vessel, with laches requiring a showing of prejudice.


Gutierrez v. Waterman S.S. Corp., 373 U.S. 206 (1963)