## Facts

- Gabriel Vincent worked as a derrick-hand on Harvey Well Service Rig #2, an inland water submersible drilling barge towed by tug.
- The crew worked offshore 12-hour shifts with 24 hours off and did not sleep aboard the rig.
- Because the worksite was remote, the employer arranged a regular shuttle: a company car transported employees between a metropolitan assembly point in Gretna, Louisiana and the Venice, Louisiana pierhead, and returned them after the shift.
- The driver was also a rig employee and was paid additional compensation per shift specifically for driving the crew.
- Crew members were permitted to use their own transportation and were not paid travel time while riding in the company car.
- After completing a shift on November 30, 1967, Vincent rode in the company car from Venice toward Gretna; about 10 miles below Gretna, the car was in a wreck and Vincent was injured.

## Issues

1. Whether a Jones Act seaman injured while off duty as a passenger in employer-furnished transportation from a remote pierhead to a regular assembly point is injured “in the course of his employment.”

## Decision

- The Fifth Circuit reversed the district court’s summary judgment for the employer and remanded.
- The court held that Vincent’s injury occurred “in the course of his employment” for Jones Act purposes.
- The court concluded that the employer’s organized, compensated shuttle arrangement tied the travel to the employment relationship despite the “off duty,” unpaid-travel, and formally optional nature of the ride.

## Legal Principles

- “Course of employment” under the Jones Act is construed broadly in light of the statute’s remedial purpose and is not limited to injuries occurring on the vessel or during active duty.
- Employer-furnished transportation can be an incident of maritime employment when it is a regular, structured means of moving a crew to and from a remote worksite.
- The facts that employees are not paid for travel time and are not formally required to use the employer’s conveyance do not necessarily remove such travel from the Jones Act’s “course of employment.”

## Conclusion

The Fifth Circuit held that a seaman injured in an automobile accident while returning from a remote pierhead in a regular employer-provided shuttle was injured in the course of employment under the Jones Act, making summary judgment for the employer improper and allowing the negligence claim to proceed on remand.


Vincent v. Harvey Well Serv., 441 F.2d 146 (5th Cir. 1971)