## Facts

- A seaman serving as a crew member aboard the steamship *Osceola* suffered serious personal injuries when a heavy steel plate fell onto his leg during shipboard work.
- The seaman alleged the injury resulted from unsafe conditions connected to the ship’s work, including a failure to provide proper appliances and a safe place or method to perform the task.
- The seaman filed a libel in admiralty **in rem** against the vessel, seeking monetary damages for his injury beyond the traditional maritime allowances of wages, maintenance, and cure.
- The federal district court entered a decree awarding damages to the seaman.
- The circuit court of appeals affirmed the award, treating the claim in a manner similar to passenger recovery for negligence.
- The shipowners sought Supreme Court review, arguing that under general maritime law a seaman may not recover tort-style indemnity for injuries caused solely by the negligence of the master or fellow crew members, and that the proper remedies are limited to wages, maintenance and cure, and (when proven) recovery for unseaworthiness or defective appliances.

## Issues

1. Whether, under general maritime law, a seaman may recover indemnity (damages) from the ship or its owners for personal injuries caused by the negligence of the master or fellow seamen.
2. Whether the vessel and her owners are liable in rem to indemnify a seaman when the injury is caused by the ship’s unseaworthiness or by failure to supply and keep in order proper appliances appurtenant to the ship.
3. What obligations general maritime law imposes on ship and owners concerning wages, maintenance and cure, and medical care when a seaman is injured in the service of the ship.

## Decision

- The Supreme Court reversed the damages decree insofar as it rested on negligence of the master or crew, holding that general maritime law (as then understood) provided **no general right** for a seaman to recover indemnity for such negligence.
- The Court restated the established maritime obligations owed to seamen injured in the service of the ship, including **maintenance and cure** and **wages to the end of the voyage**.
- The Court confirmed that the vessel and her owners may be liable **in rem** to indemnify a seaman when the injury is caused by **unseaworthiness** or by a **failure to supply and keep in order proper appliances** for the ship’s work.
- On the record as treated by the courts below, the recovery had been granted on a negligence theory rather than on a proven unseaworthy condition, so the damages award could not stand.

## Legal Principles

- A seaman who becomes ill or is injured while in the service of the ship is entitled to **maintenance and cure**, including such medical care as the situation requires, without regard to fault.
- When a seaman is injured in the service of the ship, the maritime law obligates the shipowner to pay **wages to the end of the voyage** (subject to the employment terms and the voyage’s completion).
- The vessel and her owners are liable **in rem** to indemnify a seaman for injuries caused by the **unseaworthiness of the ship** or by a **failure to supply and keep in order proper appliances appurtenant to the ship**.
- General maritime law (as stated in 1903) provides **no indemnity** to a seaman for personal injuries caused solely by the **negligence of the master or any member of the crew**, distinguishing seamen from passengers with respect to negligence recovery.

## Conclusion

*The Osceola* restated the classic rules of general maritime law governing seamen’s remedies: wages to the end of the voyage and maintenance and cure for injuries incurred in the ship’s service, plus indemnity in rem for injuries caused by unseaworthiness or defective ship’s appliances, but no general maritime-law tort recovery for injuries attributed only to negligence of the master or fellow crew members.


*The Osceola*, 189 U.S. 158 (1903)

The Osceola, 189 U.S. 158 (1903)