Naquin v. Elevating Boats, LLC: The Fifth Circuit’s Improper Expansion of Jones Act “Seaman Status” Qualification

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The story began nearly a century ago, when Congress enacted the Jones Act and effectively made “seamen the most generously treated personal injury victims in American law.” But defining a Jones Act seaman has not come easy, as it took the United States Supreme Court seventy five years to arrive at the modern seaman status test. This commentary examines the “tortured history” of the Jones Act, how qualification for the statute’s protections has evolved, the modern seaman status test, and the implications of the Fifth Circuit’s recent application thereof. Section II gives a brief history and explanation of maritime law in the United States and the sources of federal court jurisdiction over maritime cases. Section III discusses pre-Jones Act maritime personal injury claims and the significance that the statute’s enactment has had on the maritime industry. Section IV discusses the evolution of the seaman status test to the modern framework. Section V discusses the Fifth Circuit’s decision in Naquin v. Elevating Boats, L.L.C. Section VI discusses the implications of this holding and proposes an adjustment to the seaman status test.