## Facts

- Hawn, a carpenter employed by an independent contractor, was hired to repair and maintain a grain-loading spout used to load cargo onto a vessel owned/operated by Pope & Talbot, Inc.
- The work occurred aboard the vessel while it was moored in navigable waters during cargo-loading operations.
- Hawn fell and was injured due to an unguarded or inadequately safeguarded deck opening/hatch in the work area.
- Evidence supported a finding that ship personnel left the opening in a hazardous condition without adequate cover, guardrails, or warning.
- Hawn was not a member of the vessel’s crew but was performing ship-related work connected to the vessel’s maritime activity.

## Issues

1. Whether federal maritime law or a forum state’s contributory negligence rule governs liability for a personal injury occurring aboard a vessel on navigable waters.
2. Whether a non-crew worker injured while performing ship-related work aboard a vessel may invoke maritime tort remedies, rather than being limited to state-law remedies.
3. Whether the plaintiff’s own negligence bars recovery or merely reduces damages in a maritime personal-injury action.

## Decision

- The Supreme Court affirmed the judgment for Hawn.
- Federal maritime law governed because the injury arose from a maritime tort on navigable waters in connection with maritime operations.
- Pennsylvania’s contributory negligence rule could not be applied to bar recovery.
- Any negligence by Hawn operated only to diminish damages, not to defeat the claim.

## Legal Principles

- A tort occurring on navigable waters in connection with maritime activity is governed by federal maritime law rather than conflicting state tort rules.
- In maritime personal-injury actions, contributory negligence is not a complete defense; it reduces damages in proportion to the plaintiff’s fault.
- State law may not be used to deny or narrow substantive rights provided by maritime law.
- A worker who is not a seaman or crew member may still recover under maritime tort doctrines when injured aboard a vessel on navigable waters while performing ship-related maritime work.

## Conclusion

The Court held that a non-crew worker injured aboard a vessel on navigable waters could recover under federal maritime law, and that state contributory negligence could not bar the claim because maritime comparative fault governs and reduces, rather than eliminates, damages.


Pope & Talbot, Inc. v. Hawn, 346 U.S. 406 (1953)