Case Law

Date Decided: April 6^th, 2010

Originally Filed in: Pennsylvania (Federal)

Decided by: U.S. Court of Appeals, Third Circuit (Federal)

Court: The United States Court of Appeals for the Third Circuit

Judge: Judge Jordan

Citation: 2010 WL 1303464 (3rd Cir. 2010)

Background:
Mon River Towing Inc., JAR Barge Lines, LP appeal from a judgment entered against them by the US District Court for the Western District of Pennsylvania requiring them to pay $296,000 in attorney’s fees to Ingram Barge Co.

The underlying action involved a claim under the Jones Act brought by a JAR Barge Lines seaman. The issue in this appeal, however, was whether JAR Barge Lines and other defendants were required to indemnify Ingram for the attorney’s fees Ingram incurred while defending against a lawsuit brought by one of JAR’s seaman.

In its decision to indemnify Ingram, the District Court relied upon the Ryan doctrine (set forth in Ryan Stevedoring v. Pan-Atlantic Steamship Corp (350 U.S. 124). The Ryan doctrine allows a shiponwer to recover indemnity from a marine contractor when the shipowner has ceded control of the ship to the contractor for the performance of certain services and the contractor’s improper performance of services, exposing the shipowner to an unseaworthiness claim.

Issues:
Did the District Court err in indemnifying the ship owner?

Held:
Appellants argued that Ryan is an outdated relic of admiralty law that should be abandoned. According to the Appellants, the 1972 amendments to the LHWCA and other circuit decisions have retreated from its application.

However, this Court recognized that Ryan was still binding, in the 3^rd Circuit, as applied in the seaman context long after the 1972 LHWCA amendments.

Accordingly, this Court found that the district court did not err in affirming the lower court’s judgment and held that Ingram was entitled to indemnity.

Comments:
The Ryan doctrine was in the context of an injured longshoreman who was covered by the LHWCA and was designed to alleviate the shipowner’s absolute liability under the unseaworthiness doctrine in situations where the shipowner has relinquished control of some operations on the vessel to the stevedore.

As such, this doctrine has also been extended to ship-repairers and may hold them liable for injury caused by their negligence.