## Facts

- Swanson was a longshoreman employed by Marra Bros., a stevedoring company.
- While working on a pier in Philadelphia loading cargo onto a vessel moored alongside, a life raft fell from the vessel and struck him, causing injury.
- Swanson sought and received compensation under Pennsylvania’s employers’ liability law.
- He later filed a federal action against his employer alleging negligence, including failure to provide a safe place to work and to secure and inspect the life raft.
- The district court dismissed the complaint; the Third Circuit affirmed; the Supreme Court granted review to resolve whether the Jones Act permitted the suit.

## Issues

1. Whether a longshoreman injured on a pier while loading a vessel may sue his employer for negligence under the Jones Act.
2. Whether subsequent federal statutes, especially the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA), limited Jones Act remedies to “members of the crew” and otherwise directed non-crew maritime workers to different remedies.

## Decision

- The Supreme Court affirmed dismissal of the complaint.
- A longshoreman injured on shore (on a pier) has no right of recovery against his employer under the Jones Act.
- Subsequent legislation after the Jones Act restricted employer liability under federal maritime statutes to (i) injuries occurring on navigable waters for covered workers under the LHWCA and (ii) injuries to masters or members of a vessel’s crew within the Jones Act.
- Because the LHWCA covers only injuries occurring on navigable waters, it does not apply to shore injuries like Swanson’s; in such cases, non-crew employees are left to local (state) law remedies.
- The Court stated that Jones Act rights of true crew members remain available when they are injured while pursuing their maritime employment, whether on ship or on shore.

## Legal Principles

- The Jones Act’s negligence remedy is confined to “seamen,” understood in the post-LHWCA statutory scheme as masters and members of a vessel’s crew.
- The LHWCA substituted a federal compensation remedy for non-crew maritime employees injured on navigable waters and, by doing so, displaced broader pre-LHWCA readings that treated some stevedores as “seamen” for Jones Act purposes.
- Injuries to non-crew maritime employees inflicted on shore fall outside the LHWCA’s geographic coverage and do not create a Jones Act cause of action against the employer; the worker must rely on state law remedies.

## Conclusion

The Court held that a longshoreman employed by a stevedoring company and injured on a pier while loading a vessel cannot sue his employer under the Jones Act; after enactment of the LHWCA, Jones Act liability was limited to crew members, while other maritime workers’ remedies depend on compensation statutes for water-based injuries and state law for shore-based injuries.


Swanson v. Marra Bros., Inc., 328 U.S. 1 (1946)