Stewart v. Dutra Constr. Co., 543 U.S. 481 (2005)

In the case of Stewart v. Dutra Construction Co., 543 U.S. 481 (2005), the underlying events revolve around an accident involving Willard Stewart, a marine engineer employed by Dutra Construction Company. Stewart was tasked with maintaining the mechanical systems of the Super Scoop, a large dredge used in the Central Artery/Tunnel Project in Boston, known as the "Big Dig." During his work, while on board Scow No. 4, which was experiencing an engine malfunction, the Super Scoop moved the scow using its clamshell bucket. This movement caused a collision that resulted in Stewart falling through an open hatch and sustaining serious injuries. The procedural history of the case began when Stewart filed a lawsuit in the United States District Court for the District of Massachusetts. He claimed damages under the Jones Act, asserting that he was a seaman injured due to Dutra’s negligence, and also made an alternative claim under the Longshore and Harbor Workers' Compensation Act (LHWCA) for injuries caused by a vessel owner’s negligence. Dutra Construction Company sought summary judgment, arguing that Stewart was not a seaman and that the Super Scoop did not qualify as a vessel under the relevant statutes. The relevant background context includes the characteristics of the Super Scoop, which, while possessing some features of a seagoing vessel (such as a crew and navigational lights), lacked full self-propulsion capabilities, relying instead on tugboats for long-distance movement. The case raised significant questions about the definition of a "vessel" under the LHWCA, as the determination of whether the Super Scoop qualified as a vessel would affect Stewart's eligibility for claims under maritime law. The case ultimately reached the Supreme Court on a writ of certiorari to resolve this critical issue.

Whether a dredge is considered a "vessel" under the Longshore and Harbor Workers’ Compensation Act (LHWCA), 33 U.S.C. §902(3)(G).

The judgment is reversed.