In Jefferson v. Weeks Marine, Inc., et al., C.A. No. 15-240 (E.D. La. 2/3/16), a district court in the Eastern District of Louisiana recently ruled that a land-based yard worker who was injured aboard a barge did not qualify as a seaman under the Jones Act because he failed to satisfy the temporal requirements for seaman status. As we advised in our April 2014 and August 2014 newsletters, a 2014 Fifth Circuit decision, Naquin v. Elevating Boats, L.L.C., 744 F.3d 927 (5th Cir. 2014), arguably expanded the scope of Jones Act status for land-based workers, especially those working in a shipyard context. Yet, in ruling on the issue of seaman status in Jefferson, the district court declined to rely on Naquin, instead focusing on the “substantial connection” test first articulated by the United States Supreme Court in Chandris v. Latsis, 515 U.S. 347, 354 (1995). Continue reading >