Legal Updates on Maritime Workers' Personal Injury Claims: Sanchez v. Smart Fabricators


Sanchez v. Smart Fabricators of Texas is a recently decided case that will most likely be often used in seaman status disputes by vessel employers to challenge seaman status. Your seaman status has a huge impact on the remedies you are entitled to and the damages that you can recover. What allows an injured maritime worker to get compensated as a Jones Act seaman? Discover more about Sanchez’s case.

Sanchez’s Personal Injury Case

Sanchez worked as a welder for Smart Fabricators aboard an offshore jack-up drilling rig at the time of the accident. The company does not own or operate any jack-up drill rigs but solely provides fabrication and equipment repair services to its jack-up rig customers.

Sanchez was a welder, who was injured by tripping on a pipe welded to the deck. He attempted to claim seaman status as that would entitle him to sue his employer for negligence under the Jones Act. Sanchez worked for Smart Fabricators for a total of 67 days and all but two were aboard jack-up rigs. However, 70% of that time was spent aboard a jack-up drilling rig that was adjacent to a pier steps from the shore, meaning he was only exposed to the perils of the sea for 30% of his employment time.  Would that qualify him as a seaman?

Like most seaman status disputes, this one inevitably focused on one major requirement –  Sanchez’s connection to a vessel or fleet of vessels. The rule of thumb for vessel connection is that it should be substantial in both duration and nature. Smart Fabricators challenged that the welder did not meet this requirement, specifically that his connection to a vessel or fleet of vessels was not substantial in nature because he was not exposed to the perils of the sea.

Takeaways From Seaman Status Disputes

The United States Court of Appeals for the Fifth Circuit held that Sanchez’s connection to the jack-up rig was substantial in duration (since he spent all but a few days aboard vessels), but held that his connection was NOT substantial in nature. So, working on the drilling rigs while they were jacked up and secured near an adjacent pier didn’t qualify the welder for seaman status, because he wasn’t exposed to the perils of the sea.

Whether or not you qualify as a seaman has a huge impact on your rights and remedies. Marine and energy defendants will challenge seaman status if the circumstances allow every chance they get by relying on Sanchez. See yet another practical example for the vessel connection requirement.