Houston General Insurance v. Offshore Logistics, Inc.

587 F. Supp. 824, 1984 U.S. Dist. LEXIS 16278
CourtDistrict Court, E.D. Louisiana
DecidedMay 30, 1984
DocketCiv. A. No. 82-5882
StatusPublished

This text of 587 F. Supp. 824 (Houston General Insurance v. Offshore Logistics, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Houston General Insurance v. Offshore Logistics, Inc., 587 F. Supp. 824, 1984 U.S. Dist. LEXIS 16278 (E.D. La. 1984).

Opinion

OPINION

ARCENEAUX, District Judge.

This is an action under § 33(b) of the Longshoremen and Harbor Workers’ Compensation Act, 33 U.S.C. § 901 et seq. (the Act), in which a compensation carrier alleges that it is the assignee of the rights of an injured longshoreman, and therefore proceeds against a third party vessel owner whose negligence allegedly caused those injuries. The case was tried to the Court without a jury on November 3, 1983, and taken under submission. The Court now issues its opinion in which it finds that because the plaintiff failed to demonstrate that it was assigned the rights of the injured longshoreman, the plaintiff may not assert longshoreman’s rights against the defendant. Accordingly, judgment will be entered in favor of the defendant.

FACTS

Plaintiff in this matter, Houston General Insurance Company (Houston General), is a foreign insurance company authorized to do and doing business within the State of Louisiana and within the jurisdiction of this Court. Houston General was the Longshoremen’s and Harbor Workers’ Compensation carrier for Arrow Contractors of Jefferson, Inc. (Arrow), the employer of Mr. Charles Miller. Defendant in this matter, Offshore Logistics, Inc. (Offshore Logistics), was and is now a domestic marine transport corporation authorized to do business within the State of Louisiana and within this Court’s jurisdiction. Offshore Logistics was the owner and operator of the M/V STONEWALL JACKSON on November 16, 1980. Jurisdiction and venue are uncontested.

To facilitate the conduct of its oil exploration and development activities, the Marathon Oil Company time chartered the STONEWALL JACKSON from Offshore Logistics to provide certain offshore services to Marathon platforms in the Gulf of Mexico. Marathon also engaged Arrow to provide roustabouts to perform work on its platforms. Pursuant to this contract, on November 16, 1980, Miller, an employee of Arrow, was assigned to the STONEWALL JACKSON to assist in unloading cargo from the various Marathon platforms for transport to shore. Miller was injured when a wave washed over the stern of the STONEWALL JACKSON and pushed a large box against him, pinning his leg to the deck. Miller was then transported to the hospital where he received medical treatment for the injury to his leg.

Miller filed a claim for compensation with the deputy commissioner of the De[826]*826partment of Labor. Houston General voluntarily made temporary disability payments to Miller from November 17, 1980 until July 12, 1981, in the amount of $332.79 per week for a total of $11,314.86. Houston General also paid $7,584.40 of Miller’s medical expenses. On May 25, 1982, Houston General made a final disability payment to Miller in the lump sum of $27,-288.78. All told, Houston General paid $38,603.58 either directly to Miller or on his behalf.

Six months after receiving his final lump sum payment, Miller had not filed suit to recover for his injuries against any third parties. Consequently, on December 22, 1982, Houston General filed this suit against Offshore Logistics, alleging that “33 U.S.C. Section 933(b) of the LHWCA grants an assignment in favor of the employer to recover the compensation benefits tendered by the employer to the injured employee ... [and that] Section 933(h) of the Act subrogates the employer’s compensation insurance carrier to all rights of the employer.” Complaint, at H VIII. However, in neither its complaint nor in the pretrial order did Houston General allege that because, as Arrow’s compensation carrier, it had paid Miller compensation benefits, it was entitled to indemnity therefor from Offshore Logistics. Indeed, in its post-trial memorandum to the Court, Houston General asserted that “this action has never been pled as an indemnity action by Houston General. All pleadings filed prior to this action were styled as an assignment.” Plaintiff’s post-trial memorandum of law, Record, document no. 32 at 10. Strictly speaking, Houston General is asserting (through Arrow) only the rights of Charles Miller, and not its own. To have a right of action against Offshore Logistics, Houston General must show that, under the Act, it acquired Miller’s rights. If it has not so gained Miller’s rights, then Houston General has failed to state a claim against Offshore Logistics. Consequently, the dispositive issue before the court is whether Houston General was validly assigned the rights of Charles Miller against Offshore Logistics.

LAW

The Longshoremen’s Act provides a comprehensive scheme governing the rights of an injured longshoreman. If, as is generally true in cases where a longshoreman files a claim under the Act, and his employer does not contest liability, the employer must pay compensation to the disabled longshoreman within two weeks of learning of his injury, 33 U.S.C. § 914, 20 CFR 702.231-702.232, and must file an appropriate form, Form LS-206, with the Deputy Commissioner of the Department of Labor. 33 U.S.C. § 914; 20 CFR 702.-234.

When an employer controverts a compensation claim or the injured longshoreman contests actions taken by the employer with respect to his claim, the dispute may be resolved in administrative proceedings. 33 U.S.C. § 919. If the dispute cannot be resolved informally under procedures developed by the Department of Labor, 20 CFR 702.301-702.319, the contested claim will proceed to a formal hearing before an administrative law judge, which culminates in the entry of an order by the Deputy Commissioner “reject[ing] the claim or mak[ing] an award in respect of the claim.” 33 U.S.C. §§ 919(c), 919(e). However, employers are not required to contest their liability in order to obtain a formal compensation award. Department of Labor regulations permit an employer who makes voluntary payments to obtain a compensation order upon request if there is no disagreement among the parties. 20 CFR 702.-315(a). An order making an award, referred to as “a compensation order,” 33 U.S.C. § 919(e), is reviewable by the Benefits Review Board, 33 U.S.C. § 921(b), and enforceable in federal court. 33 U.S.C. § 921(d). An employer’s failure to make timely payments under a compensation order results in a substantial penalty. 33 U.S.C. § 914(f).

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Bluebook (online)
587 F. Supp. 824, 1984 U.S. Dist. LEXIS 16278, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houston-general-insurance-v-offshore-logistics-inc-laed-1984.