## Facts

- Reynaldo Oyuela, a Honduran citizen, worked as a second engineer aboard the M/V SMIT LLOYD 25, an oil-field supply vessel operating off the coast of Nigeria.
- The M/V SMIT LLOYD 25 transported cargo and supplies between the Port of Calabar, Nigeria, and a jack-up drilling rig located in Nigerian territorial waters.
- The vessel flew the flag of St. Vincent and the Grenadines and was owned by a SEACOR-related offshore entity.
- Oyuela alleged he injured his back in the engine room while attempting to move a heavy deck plate from its stowed position, allegedly slipping on grease while lifting.
- Oyuela filed suit in the United States District Court for the Eastern District of Louisiana against multiple SEACOR-related entities; by the time of the decision, the remaining defendants included Seacor Marine (Nigeria), Inc., Seacor Marine, Inc., and Seacor Marine (Bahamas) Inc.
- One key defendant for jurisdictional purposes, Seacor Marine (Bahamas) Inc., was a foreign corporation that maintained corporate offices but allegedly owned no tangible assets in the United States and relied on other SEACOR entities for operational support.
- Oyuela personally served process on Lenny Dantin, a corporate officer of Seacor Marine (Bahamas) Inc., at SEACOR offices in Morgan City, Louisiana.
- At the time of service, Dantin was physically present in Louisiana by choice, worked there, and had lived there for several years.
- The district court held an evidentiary hearing to resolve, among other matters, personal jurisdiction, the effect of 46 U.S.C. § 688(b), and whether the case should be dismissed on forum non conveniens grounds.

## Issues

1. Whether the Eastern District of Louisiana could exercise personal jurisdiction over Seacor Marine (Bahamas) Inc. based on in-forum service of process on its corporate officer who was voluntarily present in Louisiana, together with the company’s connections to the forum.
2. Whether 46 U.S.C. § 688(b) barred Oyuela, a foreign seaman injured in foreign territorial waters on a foreign-flag vessel, from pursuing Jones Act and U.S. general maritime law remedies in a U.S. court.
3. Whether, given the foreign locus of the accident and the availability of a foreign forum, the action should be dismissed on forum non conveniens grounds in favor of litigation in the United Kingdom, subject to protective conditions.

## Decision

- The court held it had personal jurisdiction over Seacor Marine (Bahamas) Inc.
- The court found jurisdiction proper based on service on a corporate officer physically present in Louisiana and on the defendant’s forum-related ties, including its close operational relationship with SEACOR entities conducting business through Louisiana.
- The court held that 46 U.S.C. § 688(b) precluded Oyuela’s Jones Act and U.S. general maritime law claims because he was a foreign seaman injured in the territorial waters of a foreign nation aboard a foreign-flag vessel, placing the case within the statutory limitation on such U.S. remedies.
- The court conditionally dismissed the action on forum non conveniens grounds in favor of the United Kingdom.
- The dismissal was conditioned on defendants’ commitments that protected Oyuela’s ability to pursue the case abroad (including submitting to U.K. jurisdiction, addressing limitations defenses as required by the court’s order, and agreeing to satisfy any resulting judgment), with deadlines and procedural conditions for refiling.

## Legal Principles

- Personal jurisdiction may be established over a foreign corporate defendant when a corporate officer is properly served while physically present in the forum and the circumstances make exercising jurisdiction consistent with due process.
- Even when a corporation is foreign and claims minimal independent U.S. assets, a court may consider the corporation’s actual forum-directed activity and its reliance on affiliated entities operating in the forum when assessing fairness and due process.
- Under 46 U.S.C. § 688(b), Congress limited access to Jones Act and related U.S. maritime remedies for foreign seamen injured in foreign territorial waters on foreign-flag vessels when the statutory criteria are met; when applicable, the statute bars those U.S. claims.
- Forum non conveniens permits dismissal when an adequate alternative forum exists and the balance of private and public interest factors favors litigation abroad, especially where the dispute centers on foreign events, foreign witnesses and records, and the likely application of foreign law.
- A forum non conveniens dismissal may be conditioned to reduce prejudice to the plaintiff, such as requiring defendants to accept service and jurisdiction in the alternative forum, address time-bar defenses as ordered, and satisfy an enforceable foreign judgment.

## Conclusion

The Eastern District of Louisiana found it could exercise personal jurisdiction over Seacor Marine (Bahamas) Inc. based on service on its officer in Louisiana and related forum ties, but it held that 46 U.S.C. § 688(b) foreclosed Oyuela’s Jones Act and U.S. general maritime law remedies for a foreign-injured, foreign seaman on a foreign-flag vessel; with U.S. remedies barred and the dispute largely foreign, the court conditionally dismissed the case on forum non conveniens grounds in favor of proceedings in the United Kingdom.


Oyuela v. Seacor Marine (Nigeria), Inc., 290 F. Supp. 2d 713 (2003)