## Facts

- Elizabeth Wilson worked for Zapata Off-Shore Company on an offshore drilling rig from 1980 until October 1984 and advanced through several positions with substantial pay increases.
- Wilson alleged that male coworkers subjected her to repeated sexual advances and that, after she rejected them, they threatened her job status and interfered with job advancement opportunities.
- In March 1984, Wilson filed an EEOC charge alleging sex discrimination and sexual harassment, later pursuing a Title VII claim based on those allegations.
- Wilson left Zapata in October 1984 while experiencing emotional problems and was hospitalized shortly thereafter for anxiety-related conditions; she later received psychiatric treatment and attributed her condition to a hostile work environment.
- In July 1985, Wilson filed a Longshore and Harbor Workers’ Compensation Act (LHWCA) claim based on the same general events; an administrative law judge denied benefits in September 1986, finding Wilson was a “seaman” (making the Jones Act the proper remedial scheme rather than the LHWCA).
- In August 1987, Wilson filed a separate suit under the Jones Act and general maritime law seeking damages for emotional distress.
- The district court consolidated the Title VII case (bench trial) with the Jones Act/maritime case (jury trial).
- During trial, Zapata offered a hospital record that included a statement by Wilson’s sister to a social worker describing Wilson as “a habitual liar and [had] been all of her life.” Over Wilson’s objection, the district court admitted the record; other evidence also challenged Wilson’s credibility.
- In the Jones Act/maritime case, the district court applied the three-year limitations period, restricted the jury’s consideration to any injury occurring within that period, and removed from the jury claims tied solely to earlier time-barred injury.
- The jury found Wilson was not injured within the limitations period, and the district court entered a take-nothing judgment on the Jones Act/maritime claims.
- On the Title VII claim, the district court found Wilson did not prove unlawful sex discrimination or actionable harassment and entered judgment for Zapata.
- Wilson appealed, challenging the limitations rulings and trial management of the Jones Act case, the admission of the hospital record, and the adequacy and correctness of the district court’s Title VII findings.

## Issues

1. Whether Wilson’s Jones Act and general maritime emotional-distress claims were barred by the three-year statute of limitations, including whether limitations was suspended by her LHWCA proceeding, delayed by a discovery-based accrual theory, or saved by a continuing-tort theory.
2. Whether the district court erred by limiting evidence and jury consideration to injury within the limitations period and by taking from the jury any claim based solely on injury outside the limitations window.
3. Whether admitting the hospital record containing Wilson’s sister’s statement attacking Wilson’s truthfulness was reversible error.
4. Whether the district court’s findings and conclusions on the Title VII claim were adequate under Rule 52(a) and whether its no-discrimination/no-harassment determinations were clearly erroneous.

## Decision

- The Fifth Circuit affirmed the district court’s judgments for Zapata on all claims.
- The court held Wilson’s Jones Act/general maritime claims were untimely under the three-year limitations period and were not saved by her LHWCA filing, a delayed-accrual theory, or a continuing-tort theory in light of the jury’s finding of no injury within the limitations period.
- The court found no reversible error in the district court’s limitation of the jury’s consideration to timely injury and its handling of time-barred components of the Jones Act/maritime case.
- The court rejected Wilson’s challenge to the hospital-record evidence as a basis for reversal, concluding that the evidentiary ruling did not warrant disturbing the judgment given the overall record and the trial court’s role in assessing credibility.
- The court held the district court’s Title VII findings were sufficient for appellate review and were supported by the evidence, including credibility determinations.

## Legal Principles

- Jones Act personal-injury claims are governed by a three-year statute of limitations; a claim accrues when the plaintiff knew or should have known of the injury and its alleged cause.
- Pursuit of an LHWCA compensation claim does not, by itself, suspend the running of the Jones Act limitations period for a later-filed Jones Act suit.
- A continuing-tort theory does not preserve an otherwise stale claim where the factfinder determines the plaintiff suffered no actionable injury within the limitations period.
- A district court may structure proof and jury instructions around timely injury when limitations is dispositive, and appellate courts will not reverse absent prejudicial error.
- Evidentiary rulings are reviewed for abuse of discretion, and an evidentiary mistake warrants reversal only if it affects substantial rights in light of the full trial record.
- In a bench-tried Title VII claim, findings satisfy Rule 52(a) if they permit meaningful appellate review; appellate courts defer heavily to the trial judge’s credibility determinations and reverse fact findings only for clear error.

## Conclusion

Wilson v. Zapata Off-Shore Co. affirmed a defense judgment after consolidated bench and jury trials, holding that Wilson’s Jones Act/general maritime emotional-distress claims were untimely and not saved by her LHWCA proceeding or other accrual theories, that the district court’s trial and evidentiary rulings (including admission of a hospital record containing a damaging credibility statement) did not justify reversal, and that the district court’s Title VII findings rejecting harassment and discrimination were adequately stated and supported by the record.


Wilson v. Zapata Off-Shore Co., 939 F.2d 260 (1991)