Jordain Brasseaux v. Southern Alabama Marine Logistics LLC et al

CourtDistrict Court, W.D. Louisiana
DecidedJanuary 13, 2026
Docket6:24-cv-00144
StatusUnknown

This text of Jordain Brasseaux v. Southern Alabama Marine Logistics LLC et al (Jordain Brasseaux v. Southern Alabama Marine Logistics LLC et al) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jordain Brasseaux v. Southern Alabama Marine Logistics LLC et al, (W.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

JORDAIN BRASSEAUX CASE NO. 6:24-CV-00144

VERSUS JUDGE ROBERT R. SUMMERHAYS SOUTHERN ALABAMA MARINE MAGISTRATE JUDGE CAROL B. LOGISTICS LLC ET AL WHITEHURST

REPORT AND RECOMMENDATION

Before the Court is the Rule 12(b)(6) and Rule 12(b)(3) Motion to Dismiss, Alternative Motion to Transfer, filed by Defendants, Southern Alabama Marine Logistics, LLC, Crescent Marine Logistics, LLC, Kenneth Noel and Devin Noel. (Rec. Doc. 49). Plaintiff opposed the motion. (Rec. Doc. 57). The motion was referred to the undersigned magistrate judge for review, report, and recommendation in accordance with the provisions of 28 U.S.C. §636 and the Court’s standing orders. Considering the evidence, the law, and the parties’ arguments, and for the following reasons, the Court recommends that Defendants’ motion be granted in part and denied in part. Facts and Procedural History Plaintiff filed this Jones Act suit in February 2024 against the four named Defendants following an alleged February 2021 incident. He alleges that while among the crew of a dredge vessel, he was thrown to the ground due to the operator and supervisor’s excessive speed and the vessel’s instability. He alleges seaman status and seeks maintenance and cure and damages. (Rec. Doc. 1).

Following substantial delays due to Plaintiff’s inability to serve defendants and a later reversed default (Rec. Doc. 37-38), in response to Defendants’ initial motion to dismiss, Plaintiff filed an amended complaint. (Rec. Doc. 47). Defendants

now move to dismiss the individual defendants, Kenneth Noel and Devin Noel, alleged to be the operator and supervisor, respectively, and to dismiss the case for improper venue, and alternatively seeking transfer to the Eastern District of Louisiana.

Law and Analysis I. Motion to Dismiss Individual Defendants. The individual Defendants, Devin Noel and Kenneth Noel, move to dismiss

Plaintiff’s claims pursuant to F.R.C.P. Rule 12(b)(6). When considering a motion to dismiss for failure to state a claim, the district court must limit itself to the contents of the pleadings, including any attachments and exhibits thereto. Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498 (5th Cir.2000); U.S. ex rel. Riley v. St. Luke's

Episcopal Hosp., 355 F.3d 370, 375 (5th Cir.2004). The court must accept all well- pleaded facts as true and view them in the light most favorable to the plaintiff. In re Katrina Canal Breaches Litigation, 495 F.3d 191, 205 (5th Cir.2007). Conclusory

allegations and unwarranted deductions of fact are not accepted as true. Kaiser Aluminum & Chemical Sales v. Avondale Shipyards, 677 F.2d 1045, 1050 (5th Cir. 1982); Collins v. Morgan Stanley, 224 F.3d at 498. The law does “not require

heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570, 127 S. Ct. 1955, 1974 (2007). The allegations must be sufficient “to raise a right to relief

above the speculative level,” and “the pleading must contain something more …than…a statement of facts that merely creates a suspicion [of] a legally cognizable right of action.” Id. at 555 (quoting 5 C. Wright & A. Miller, Federal Practice and Procedure § 1216, pp. 235-36 (3d ed. 2004)).

The Jones Act provides an injured seaman a cause of action against his employer. The law is well-settled that “[a] seaman may not recover against a co- employee for negligence.” Hussaini v. Marine Transp. Lines, Inc., 158 F.3d 584 (5th

Cir. 1998), citing Roth v. Cox, 210 F.2d 76, 78 (5th Cir.1954), aff'd, 348 U.S. 207 (1955). “Moreover, an action under the GML for breach of the warranty of unseaworthiness and for maintenance and cure exists only against vessel owners or operators.” Pearson v. Rowan Companies, Inc., 674 F. Supp. 558, 559–60 (E.D. La.

1987), citing Vincent v. Penrod Drilling Co., 372 So.2d 807 (La.App.3d Cir.1979), writ denied, 375 So.2d 646 (La.1979); Stallworth v. McFarland, 350 F. Supp. 920, 928 (W.D. La. 1972), aff'd, 493 F.2d 1354 (5th Cir. 1974) (“It is only the owner or

operator of a vessel who owes a seaman the obligation to provide a seaworthy vessel.”). As a special class of claims, maritime claims are only permissible against co-employees for intentional torts. Pearson, 674 F. Supp. At 561-62.

Plaintiff alleges Southern Alabama and Crescent Marine operated a joint dredging operation with joint employees, crews, and supervisory personnel, and that he was their employee assigned to work aboard their dredge boat. (Rec. Doc. 47,

¶11-14). Plaintiff asserts that on the date of accident, “Employers—controlled and supervised by the Operator and Supervisor,” who the Amended Complaint defines respectively as Kenneth Noel and Devin Noel, took the dredge to inspect a crew boat when the accident occurred. (¶4; 5; 15 et seq). The allegations show that the Noels

were neither Plaintiff’s employer, the owner, nor operator (in the legal sense) of the vessel. That the complaint refers to Kenneth Noel as “the Operator” does not render him the “operator” contemplated by decades of maritime jurisprudence. Instead,

Plaintiff alleges that Kenneth Noel “was driving the vessel with the assistance and guidance of [Devin Noel] under extreme conditions…making the vessel unseaworthy…,” that he “was driving the vessel at an excessive rate of speed…,” and that he “continue[d] to operate the vessel wildly and dangerously.” (¶16-18).

These allegations illustrate the alleged fault of a vessel captain and crewmember. Absent allegations of an intentional tort, Plaintiff should not be permitted to proceed against the individual defendants. That an individual—not the two named employing entities, Southern Alabama and Crescent Marine—was an “operator” for purposes of liability is contrary to

Plaintiff’s own allegation that Southern Alabama and Crescent Marine operated the joint dredging operation (¶11) and defies logic. That Plaintiff (perhaps artfully) did not identity either Southern Alabama or Crescent Marine as the formal operating

entity does not save his claims against the individual defendants. Plaintiff’s claims against the individual defendants should be dismissed. II. Venue and Motion to Transfer Venue to Eastern District of Louisiana. Defendants next move to dismiss on the grounds of improper venue, arguing

that dismissed individual defendants (residents within this District) renders venue in this District improper. In considering a motion to dismiss for improper venue under F.R.C.P. Rule 12(b)(3), the court may consider (1) the complaint alone; (2) the

complaint supplemented by the undisputed facts evidenced in the record; or (3) the complaint supplemented by undisputed facts plus the court’s resolution of disputed facts. Ambraco, Inc. v. Bossclip B.V., 570 F.3d 233, 238 (5th Cir. 2009). The court must review all facts in the light most favorable to the plaintiff. Id. at 237. If the

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Related

Hussaini v. Marine Transport Lin
158 F.3d 584 (Fifth Circuit, 1998)
Collins v. Morgan Stanley Dean Witter
224 F.3d 496 (Fifth Circuit, 2000)
Smilde v. Snow
73 F. App'x 24 (Fifth Circuit, 2003)
Ambraco, Inc. v. Bossclip B.V.
570 F.3d 233 (Fifth Circuit, 2009)
Cox v. Roth
348 U.S. 207 (Supreme Court, 1955)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Roth v. Cox
210 F.2d 76 (Fifth Circuit, 1954)
In Re Volkswagen Ag Volkswagen of America, Inc.
371 F.3d 201 (Fifth Circuit, 2004)
Horihan v. Hartford Ins. Co. of the Midwest
979 F. Supp. 1073 (E.D. Texas, 1997)
Pearson v. Rowan Companies, Inc.
674 F. Supp. 558 (E.D. Louisiana, 1987)
Vincent v. Penrod Drilling Co.
372 So. 2d 807 (Louisiana Court of Appeal, 1979)
Stallworth v. McFarland
350 F. Supp. 920 (W.D. Louisiana, 1972)
Moler v. Wells
18 F.4th 162 (Fifth Circuit, 2021)
In re Volkswagen of America, Inc.
545 F.3d 304 (Fifth Circuit, 2008)

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