## Facts

- Roy Crook & Sons, Inc. owned and operated the M/V *Lady Patricia*, a vessel subject to Coast Guard inspection requirements and federal manning rules prescribing a minimum crew.
- Crook routinely operated the vessel with fewer crew members than required; at relevant times, the vessel was staffed with only two men.
- On July 4–5, 1981, the *Lady Patricia* suffered mechanical problems in the Gulf of Mexico and abandoned its anchor, marking it with an improvised buoy.
- After returning to port, Crook replaced a departing deckhand and sent the vessel back to recover the anchor and resume service operations.
- At the anchor site, the deckhand attempted for several hours to raise the anchor unsuccessfully; Captain Newell Allen then assisted.
- Captain Allen became entangled in the anchor line, was pulled overboard, and drowned; efforts to rescue him failed.
- The vessel’s understaffing was found to have contributed to the circumstances leading to Allen’s death.
- Allen’s family asserted Jones Act claims and opposed Crook’s petition seeking exoneration from or limitation of liability.

## Issues

1. Whether Crook’s violation of federal manning requirements, as a safety statute, barred any reduction of wrongful-death damages based on Captain Allen’s contributory negligence when the violation contributed to the death.
2. Whether the district court erred by applying comparative fault to reduce the claimants’ recovery despite the causative statutory manning violation.
3. Whether the claimants were entitled to the full damages amount found by the district court without diminution.

## Decision

- The Fifth Circuit reversed the district court’s damages reduction and rendered judgment for the claimants for the full amount of $384,204.
- The court held that Crook’s causative violation of federal manning requirements precluded reducing the recovery based on Captain Allen’s contributory negligence.
- Because the district court’s full-loss calculation was supported and the legal error concerned only the reduction for contributory negligence, rendition (not remand) was appropriate.

## Legal Principles

- Federal manning requirements are safety statutes aimed at protecting human life, including crew members, not merely passengers or third parties.
- When an employer-shipowner violates a safety statute and that violation contributes to a seaman’s injury or death, the employer may be barred from invoking the seaman’s contributory negligence to diminish Jones Act recovery.
- A causative statutory safety violation can displace ordinary comparative-fault reduction of damages in maritime personal-injury and wrongful-death claims.

## Conclusion

The Fifth Circuit required full Jones Act wrongful-death damages where the vessel owner’s causative violation of federal manning requirements prevented any reduction based on the decedent seaman’s contributory negligence.


Roy Crook & Sons, Inc. v. Allen, 778 F.2d 1037 (5th Cir. 1985)