Diamond Offshore Company v. Lamar Horton

CourtCourt of Appeals of Texas
DecidedMarch 2, 2006
Docket01-04-00438-CV
StatusPublished

This text of Diamond Offshore Company v. Lamar Horton (Diamond Offshore Company v. Lamar Horton) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Diamond Offshore Company v. Lamar Horton, (Tex. Ct. App. 2006).

Opinion

Opinion issued March 2, 2006



In The

Court of Appeals

For The

First District of Texas





NO. 01-04-00438-CV





DIAMOND OFFSHORE MANAGEMENT COMPANY, Appellant


V.


LAMAR HORTON, Appellee





On Appeal from the 190th District Court

Harris County, Texas

Trial Court Cause No. 2002-22966





O P I N I O N


          In this personal injury suit for negligence, unseaworthiness, and maintenance and cure under the Jones Act, appellant, Diamond Offshore Management Company (Diamond), appeals from a jury verdict awarding damages to appellee, Lamar Horton. In two issues on appeal, Diamond asserts that the evidence is factually insufficient to support the jury’s finding (1) that Horton’s injury was causally connected to and resulted from Horton’s arm injury and (2) on comparative fault, which assessed 90% of responsibility to Diamond and only 10% to Horton.

          We affirm.

Background

          Diamond’s employee, Horton, worked as a deck coordinator on an offshore drilling vessel, the Ocean Spur. At the end of October 2001, Horton and Jerry Neal, a crane operator, were attempting to move pipes in a cargo basket from one level of the Ocean Spur to a higher level, when one of the pipes, or stabilizers, suddenly struck Horton on his right arm. Horton initially complained of an arm injury, but a few months after the accident, Horton consulted Dr. Bradley Bartholomew, who later testified that the accident also caused a herniated disc in Horton’s back.

          A jury found that both parties’ negligence caused Horton’s injuries. The jury attributed 10% of negligence to Horton, with the remaining 90% to Diamond and awarded $737,664 in actual damages. In accordance with the jury’s apportionment of negligence, the trial court awarded Horton $663,906.60 and post-judgment interest. Diamond filed a “Motion For New Trial, Or In The Alternative, Motion for Remittitur.” The trial court denied Diamond’s motion for new trial, and this appeal ensued.

Jones Act

          In its first issue on appeal, Diamond argues that the evidence is factually insufficient to support the jury’s finding of negligence because there was no causal connection between the accident to Horton’s arm and his back injury.

          The Jones Act provides a cause of action for maritime workers injured by an employer’s negligence. Federal law provides that a party asserting an admiralty action may bring the action in state court. See 28 U.S.C. § 1333(1) (2000). When a state court hears an admiralty case, that court occupies essentially the same position occupied by a federal court sitting in diversity: the state court must apply substantive federal maritime law but follow state procedure. See Texaco Ref. & Mktg., Inc. v. Estate of Dau Van Tran, 808 S.W.2d 61, 64 (Tex. 1991); see also General Chem. Corp. v. De La Lastra, 852 S.W.2d 916, 920 (Tex. 1993).

          Under the Federal Employers’ Liability Act (FELA), a related statute, the causation burden is not the common law proximate cause standard. Rather, the causation burden is “whether the proofs justify with reason the conclusion that employer negligence played any part, even the slightest, in producing the injury or death for which damages are sought.” Rogers v. Missouri Pac. R.R., 352 U.S. 500, 506, 77 S. Ct. 443, 448 (1957); Landry v. Oceanic Contractors Inc., 731 F.2d 299, 302 (5th Cir. 1984). This burden has been termed “featherweight.” See Johnson v. Offshore Exp., Inc., 845 F.2d 1347, 1352 (5th Cir. 1988); Smith v. Trans-World Drilling Co., 772 F.2d 157, 162 (5th Cir. 1985). The Jones Act expressly incorporates FELA and the case law developing that statute. See Maritime Overseas Corp. v. Ellis, 971 S.W.2d 402, 406 (Tex. 1998). Thus, the causation standard under the Jones Act is the same as that under FELA. Id.; see also American Dredging Co. v. Miller, 510 U.S. 443, 456, 114 S. Ct. 981, 989–90 (1994); see also Brown & Root, Inc. v. Wade, 510 S.W.2d 408, 410 (Tex. Civ. App.—Houston [14th Dist.] 1974, writ ref’d n.r.e.).

          Jones Act Liability

          Texas courts have long recognized that in addition to a less stringent burden of proof, the standard of appellate review in a Jones Act case is also less stringent than under the common law. See Texas & Pac. Ry. v. Roberts, 481 S.W.2d 798, 800 (Tex. 1972); Brown & Root, 510 S.W.2d at 410. As with the law on causation, FELA’s standard of appellate review applies in Jones Act cases. Maritime Overseas, 971 S.W.2d at 406. Thus, the purpose of the Jones Act standard of review is to vest the jury with complete discretion on factual issues about liability. Id. Once the appellate court determines that some evidence about which reasonable minds could differ supports the verdict, the appellate court’s review is complete. See Roberts, 481 S.W.2d at 800 (citing Lavender v. Kurn, 327 U.S. 645, 66 S. Ct. 740 (1946)). Essentially, we may not conduct a traditional factual sufficiency review of a jury’s liability finding under the Texas “weight and preponderance” standard. Maritime Overseas, 971 S.W.2d at 406 (citations omitted); see also Brown & Root, 510 S.W.2d at 410. Rather, courts of appeals must apply the less stringent federal standard of review. Maritime Overseas

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Related

Lavender v. Kurn
327 U.S. 645 (Supreme Court, 1946)
Rogers v. Missouri Pacific Railroad
352 U.S. 500 (Supreme Court, 1957)
American Dredging Co. v. Miller
510 U.S. 443 (Supreme Court, 1994)
Calvin J. Smith v. Trans-World Drilling Company
772 F.2d 157 (Fifth Circuit, 1985)
Pilgrim's Pride Corp. v. Smoak
134 S.W.3d 880 (Court of Appeals of Texas, 2004)
General Chemical Corp. v. De La Lastra
852 S.W.2d 916 (Texas Supreme Court, 1993)
Hernandez v. Altenberg
904 S.W.2d 734 (Court of Appeals of Texas, 1995)
Maritime Overseas Corp. v. Ellis
971 S.W.2d 402 (Texas Supreme Court, 1998)
Brown & Root, Inc. v. Wade
510 S.W.2d 408 (Court of Appeals of Texas, 1974)
Texas and Pacific Railway Company v. Roberts
481 S.W.2d 798 (Texas Supreme Court, 1972)
Angelina Casualty Company v. Spencer
310 S.W.2d 682 (Court of Appeals of Texas, 1958)
Offshore Pipelines, Inc. v. Schooley
984 S.W.2d 654 (Court of Appeals of Texas, 1999)
TEXACO REFINING AND MARKEING, INC. v. Estate of Dau Van Tran
808 S.W.2d 61 (Texas Supreme Court, 1991)
Landry v. Oceanic Contractors, Inc.
731 F.2d 299 (Fifth Circuit, 1984)

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Diamond Offshore Company v. Lamar Horton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/diamond-offshore-company-v-lamar-horton-texapp-2006.