## Facts

- Smith, a seaman employed on Socony-Vacuum Oil Co.’s vessel, was assigned engine-room duties requiring him to check whether an engine bearing was overheated by touching it.
- To reach the bearing, Smith used a metal step in the engine room that was defective and had not been repaired despite its known condition.
- The step failed while Smith was using it, causing him to fall and suffer injuries.
- Evidence indicated Smith knew of the defect and could have performed the task using an available, known safer method that did not require the defective step.
- Smith was not specifically ordered to use the defective step and had not been instructed to avoid it.

## Issues

1. Whether assumption of risk is an available defense in a Jones Act suit when a seaman, aware of a defective appliance and a safe alternative, chooses to use the defective appliance while on duty.
2. Whether the seaman’s conduct should bar recovery as assumption of risk or merely reduce damages as comparative negligence.

## Decision

- The Supreme Court affirmed the judgment for Smith.
- Assumption of risk is not a defense in a seaman’s Jones Act action for injuries resulting from use of a defective ship’s appliance, even if the seaman knew of the defect and chose an unsafe method over a known safe alternative.
- The seaman’s own negligence, if any, is addressed under admiralty comparative negligence and mitigates damages rather than barring recovery.
- The trial court properly refused an instruction that Smith assumed the risk if he could have performed his work safely without using the defective step.

## Legal Principles

- In Jones Act cases, the employer-shipowner may not invoke assumption of risk to avoid liability for negligence in failing to provide a safe place to work or safe appliances.
- A seaman’s knowledge of a defect and decision to proceed may constitute contributory fault, but it does not operate as a complete bar; it is considered only in reduction of damages under comparative negligence.
- The shipowner’s duty to furnish safe appliances and a safe working environment remains enforceable notwithstanding the seaman’s awareness of unsafe conditions.

## Conclusion

The Court held that a shipowner cannot defeat a Jones Act claim by labeling a seaman’s knowing use of a defective appliance as assumption of risk; the proper approach is comparative negligence, which permits recovery while allowing the factfinder to reduce damages for the seaman’s contributing fault.


Socony-Vacuum Oil Co. v. Smith, 305 U.S. 424 (1939)