## Facts

- Zacharias Rhoditis, a Greek seaman, worked under a Greek employment contract selecting Greek law, a Greek collective-bargaining agreement, and Greek courts.
- He was injured aboard the Hellenic Hero while the vessel was in the Port of New Orleans.
- The Hellenic Hero was Greek-flagged and of Greek registry.
- Hellenic Lines Ltd. was a Greek corporation but maintained its largest office in New York and another office in New Orleans.
- Over 95% of Hellenic Lines’ stock was owned by Pericles G. Callimanopoulos, a Greek citizen domiciled in the United States (Connecticut) who managed the company from New York.
- The Hellenic Hero operated on regularly scheduled runs involving U.S. ports and carried cargo tied to U.S. commerce; the trial court found the vessel’s entire income derived from cargo originating or terminating in the United States.
- Rhoditis sued his employer under the Jones Act for personal injury.
- The district court entered judgment for Rhoditis; the Fifth Circuit affirmed.

## Issues

1. Whether the Jones Act applies to a foreign seaman injured in U.S. waters on a foreign-flag vessel when the foreign shipowner has substantial and continuing operational and economic connections with the United States.
2. Whether the factors used to assess Jones Act applicability are applied as a rigid checklist or as a flexible, totality-of-circumstances inquiry that considers the shipowner’s U.S. base of operations.

## Decision

- The Supreme Court affirmed the Fifth Circuit and held the Jones Act applicable.
- Although several considerations pointed to Greece (flag, seaman’s nationality, employment contract, availability of Greek courts), the shipowner’s substantial and continuing U.S. contacts outweighed them.
- The Court treated the multi-factor approach as non-mechanical and emphasized practical operational realities, including the shipowner’s base of operations and economic ties to U.S. commerce.

## Legal Principles

- Jones Act applicability to injuries involving foreign elements is determined under a flexible, totality-of-circumstances analysis rather than a rigid application of enumerated factors.
- The commonly used considerations include: place of the wrongful act, law of the flag, allegiance or domicile of the injured seaman, allegiance of the shipowner, place of contracting, accessibility of a foreign forum, and law of the forum.
- Substantial and continuing contacts between the shipowner and the United States—such as a U.S. base of operations, management from the United States, and predominantly U.S.-generated revenue—can justify applying the Jones Act even when formal indicators are foreign.
- Courts may look past formal devices (flag and contractual choice-of-law/forum terms) when the operational and economic reality shows a predominantly U.S.-centered enterprise.

## Conclusion

The Court held that the Jones Act covered a Greek seaman injured in a U.S. port on a Greek-flag vessel because the foreign shipowner’s business was, in practical operation, closely based in and economically dependent on the United States, and the governing multi-factor test must be applied flexibly to reflect those realities.


Hellenic Lines Ltd. v. Rhoditis, 398 U.S. 306 (1970)