No Right to Jury Trial on Liability for Jones Act Seaman in Limitation Act Case

On behalf of the owner of a commercial fishing vessel on which a seaman was killed, we convinced the court to decide the issues of liability and limitation of liability, rather than requiring a jury trial. Pierce Atwood commenced an action under the Shipowner's Limitation of Liability Act in the United States District Court for the Eastern District of New York on behalf of the owner of a commercial fishing vessel on which a seaman was killed, seeking to limit the owner’s liability to the value of the vessel. The decedent’s personal representative filed claims in the limitation action and demanded jury trial under the Jones Act. Pierce Atwood moved to bifurcate the case, arguing that the Limitation Act provides that until the federal court, sitting in admiralty and without a jury, decides whether the vessel owner is entitled to limit its liability, prosecution of the seaman’s claims must cease, and that, in order to determine whether the owner was entitled to limitation, the court must first determine whether the owner was liable at all. The court agreed with Pierce Atwood. It held that the interests of judicial economy were best served by bifurcation, and that the issues of liability and limitation of liability should be tried to the court rather than a jury. Given that, in Jones Act cases, only “slight causation” is necessary to prove the vessel owner’s negligence, having the court rather than a jury determine the owner’s liability is a very significant victory for the owner.