## Facts

- Paul L. Wyatt worked for Offshore Food Services, Inc. as a kitchen steward assigned to the offshore drilling rig PENROD 54, owned by Penrod Drilling Co.
- Wyatt and three other Offshore employees shared a small cabin with two upper and two lower bunks; crew members often moved in the dark to avoid waking others.
- Wyatt slept in an upper bunk that had no ladder and typically jumped down to the floor rather than step on the occupant of the lower bunk.
- Around 4:00 a.m. on September 24, 1981, Wyatt jumped down in the dark and struck a chair placed near his bunk after he went to bed, injuring his foot.
- Wyatt sued Penrod and Offshore for Jones Act negligence and unseaworthiness under general maritime law.
- The parties settled Wyatt’s maintenance-and-cure claim before trial, but Wyatt introduced some maintenance-and-cure-related evidence at trial.
- A jury found defendants liable and awarded damages; the district court denied Wyatt’s motion for prejudgment interest.

## Issues

1. Whether allowing evidence related to maintenance and cure after settlement of that claim was reversible error.
2. Whether the jury should have been instructed that Wyatt’s supervisory status imposed greater responsibility for his own safety than an ordinary seaman.
3. Whether the case was governed by admiralty law or state law via diversity, and whether the district court erred in denying prejudgment interest.

## Decision

- The Fifth Circuit affirmed the judgment in all respects.
- The court found no reversible error in admitting evidence touching on maintenance and cure despite pretrial settlement.
- The court held the district court properly refused a special “supervisory seaman” instruction; ordinary negligence and comparative-fault instructions were sufficient.
- On cross-appeal, the court held the case was tried under admiralty principles only, so Louisiana prejudgment-interest rules did not apply, and denial of prejudgment interest was proper under maritime law.

## Legal Principles

- When a plaintiff asserts exclusively maritime claims (e.g., Jones Act negligence and unseaworthiness) and no state-law causes of action, federal admiralty principles govern even if diversity jurisdiction is pleaded.
- In admiralty, prejudgment interest is governed by federal maritime law and is generally discretionary with the trial court; state interest provisions do not control merely because diversity is invoked.
- A seaman’s supervisory title does not, by itself, require a special jury instruction increasing the seaman’s legal responsibility for personal safety; comparative fault may be addressed through standard instructions.
- Settlement of a maintenance-and-cure claim does not automatically bar all trial evidence relating to maintenance and cure; reversal requires a showing of prejudicial error.

## Conclusion

The Fifth Circuit affirmed a maritime personal-injury verdict, holding that the trial was governed by admiralty law despite a diversity pleading, that the district court did not err in its evidentiary and instructional rulings, and that denial of prejudgment interest was permissible under federal maritime principles.


Wyatt v. Penrod Drilling Co., 735 F.2d 951 (5th Cir. 1984)