This case involves a Jones Act and general maritime law claim by seaman Danny Paul McGuffie, who was injured aboard Transworld's drilling rig when struck by a pipe that had catapulted out of control due to a broken ramp; the toolpusher had repeatedly refused crew requests to halt operations and repair the ramp. A jury found the defendant negligent and the vessel unseaworthy, awarding the plaintiff and his wife compensatory damages plus $500,000 in punitive damages. On the defendant's motion for judgment notwithstanding the verdict, the court modified the judgment to strike the punitive damages. The court held that, under general maritime law precedents such as The Amiable Nancy, an employer cannot be held liable for punitive damages based solely on the reckless or wanton conduct of a foreman absent evidence that corporate officials knew of or approved the conduct or were at fault in hiring the foreman.

torts & liability

The case arose after barges broke loose from a mooring device during dredging operations in Louisiana waters and damaged oil production facilities and a pipeline, leading to a settled tort claim for $140,000. The settling parties, through their insurer Fidelity & Casualty, then sought reimbursement from Aetna Casualty & Surety Company under comprehensive general liability policies issued to the dredging companies Lake Charles and Parker Brothers. The court ruled that Aetna's watercraft exclusion did not bar coverage because liability could rest on the separate, unexcluded ground of selecting and owning an inadequate mooring device, and that the insureds needed only to demonstrate potential liability under the Wisconsin Barge Line test, which they satisfied. It further held that Fidelity & Casualty could recover the portions of the settlement attributable to Lake Charles but not the amount paid on behalf of Parker Brothers alone.

business & regulatorytorts & liabilityprocedure

The Chitimacha Tribe of Louisiana sued to reclaim a large tract of land in St. Mary Parish, alleging that 1790s deeds transferring the land from the tribe to defendants' ancestors were invalid under the Indian Nonintercourse Act because they were not made at a public treaty under U.S. authority. The district court granted summary judgment to the defendants. It held that the tribe's claims were extinguished and barred by the preclusive provisions of the Louisiana Land Claims Acts, which Congress enacted after the 1803 Louisiana Purchase to establish an exclusive procedure requiring claimants to register and have titles confirmed by a board of commissioners and ultimately by Congress, with strict time limits whose violation rendered claims void.

propertyfederal powercivil rights

This case involved a personal injury attorney seeking to enjoin major liability insurance companies from publishing advertisements that he alleged improperly influenced jurors to reduce damage awards, thereby tampering with juries and obstructing justice. The court granted the defendants' motions for summary judgment and denied the requested injunction. The core reasoning was that the ads constituted protected speech on matters of public interest under the First Amendment rather than commercial speech, triggering a heavy presumption against prior restraints; although a potential conflict with fair trial rights existed, it was more remote than in precedents like Nebraska Press Association v. Stuart, and alternative safeguards such as voir dire and jury instructions could address any impact without suppressing publication.

free speechtorts & liabilityprocedure

The case concerned a constitutional challenge by an employer and prospective employee to a St. Mary Parish ordinance requiring transient workers and those seeking new jobs to register with a franchisee, submit fingerprints, photos, and personal history details, and pay a fee to obtain an employment card, enacted under state authority to address crime linked to population growth from the offshore oil industry. Plaintiffs claimed violations of the Commerce Clause, right to travel, right to privacy, equal protection, and protections against unreasonable searches and self-incrimination. The court rejected the privacy claim, concluding that the mandated disclosures did not involve sensitive personal matters within the zone protected by the Due Process Clause, as supported by precedents such as Whalen v. Roe and Paul v. Davis. It further analyzed the right-to-travel challenge under a less stringent standard than strict scrutiny, distinguishing the ordinance from cases imposing severe penalties on interstate movement.

civil rightslabor & employmentbusiness & regulatory

This case concerned claims for wrongful death and personal injuries from a single-vehicle accident in which the tread separated from a Goodyear radial tire on a new Ford Mercury Cougar, causing the car to leave the road and strike a culvert. The driver, who had a blood-alcohol level of .18% and was traveling over 100 mph, was killed, and a passenger was seriously injured. After reviewing expert testimony on tire construction, bonding, and testing standards, the court analyzed the tire's maximum safe operating speed of 85 mph against the vehicle's capabilities, the adequacy of warnings in the owner's manual, and whether the tread separation constituted a defect under Louisiana products-liability principles. The court ultimately found liability and awarded the passenger damages for medical expenses and general damages.

torts & liabilitybusiness & regulatory

This case concerned Louisiana state legislator Carl W. Bauer and his wife seeking refunds of federal income taxes paid for 1969, 1970, and 1971 based on claimed charitable contribution deductions for amounts donated to a scholarship fund benefiting high schools in Bauer's legislative district. The government contested the deductions on the merits and also asserted that the refund claims for 1969 and 1970 were barred by the two-year statute of limitations under 26 U.S.C. § 6532(a)(1) following the IRS's January 1974 disallowance notices. The court analyzed whether the notices triggered the limitations period and examined the deductibility requirements of Internal Revenue Code Section 170, ultimately ruling that the contributions qualified as deductible because they were made for the use of exempt educational organizations, the donor exercised no control over selection of individual recipients, and the funds were effectively controlled by the schools. The court therefore held that the taxpayers were entitled to the deduction for tax year 1971.

taxesprocedure

This case concerns a Jones Act personal injury suit by Harold Guidry against Soloco and Messina for damages from a fall while working on a dragline project in 1972. Messina settled with the plaintiff for $75,000 with a release, and a jury later awarded Guidry $150,000 against Soloco (reduced 9.6% for his contributory negligence). The court determined that Guidry was not a seaman as to Messina as a matter of law but allowed the jury to consider his prior connection to the vessel for the Soloco claim. It then addressed the remaining issues of whether Soloco could offset the judgment due to Messina's settlement or fault, Messina's reimbursement claim against Soloco, and Soloco's indemnity claim against Messina, analyzing maritime precedent on contribution and the compensation shield.

labor & employmenttorts & liabilityprocedure

This case involves a patent infringement suit brought by plaintiff Billy Gene Pugh against defendant Charles H. Roe and his company for manufacturing and selling stabilized personnel and cargo landing nets. The court addressed the validity of Patent 325 (covering a personnel and cargo landing net) and Patent 346 (adding a stabilizer), as well as infringement claims, after previously overruling defenses of laches and estoppel. The court concluded that Patent 325 was valid, finding it a non-obvious advance under 35 U.S.C. § 103 based on evidence of a critical industry need for safer personnel transfers offshore, the net's fulfillment of that need, and distinctions from prior art like simple cargo nets. Infringement analysis focused on differences such as rope configuration and stabilizer design between the patents and the accused products.

propertybusiness & regulatory

This admiralty case arose when Dow Chemical sued the owner of the tug M/V GULF SEAS for the loss of Dow's chemical tank barge DC-715 and its cargo after the barge sank during a tow from Freeport, Texas, to Savannah, Georgia, due to flooding from improper deballasting. The court determined that both parties were equally at fault and apportioned liability 50/50. Dow was at fault for furnishing an unseaworthy barge with a complex and malfunctioning valve system and for failing to properly instruct the tug crew on its operation despite knowing the crew lacked familiarity. The tug owner was at fault for not providing an adequate crew, including a licensed tankerman competent to handle the deballasting equipment, despite agreeing to proceed without one.

torts & liabilitybusiness & regulatory

In Reed v. Angelle, a bankruptcy proceeding involving a home construction contractor, several creditors sought to prevent the discharge of debts arising from funds advanced for specific building projects that the bankrupt allegedly misused by commingling and applying them to other purposes. The district court reviewed conflicting bankruptcy court rulings on dischargeability under 11 U.S.C. § 35(a)(4), which excepts liabilities from fraud, embezzlement, misappropriation, or defalcation while acting in a fiduciary capacity. The court held that the contractor's role created a fiduciary duty under Louisiana law, making the misapplication of funds non-dischargeable to the extent the advances were not used for the intended constructions, affirming some judgments, reversing others, and remanding one for further findings.

business & regulatorypropertycriminal law

This case involved a maritime personal injury claim by plaintiff Fruge against multiple parties for damages from three separate accidents, including two workplace incidents with Damson Drilling and a 1974 crewboat collision between vessels owned by Aucoin and Trahan in which the plaintiff was a passenger. After settling with Damson and Trahan prior to trial, the case proceeded solely against Aucoin. The court found the Aucoin vessel 75% at fault and the Trahan vessel 25% at fault for the collision, with no negligence by the plaintiff, and determined that the plaintiff's nerve root compression resulted from the collision based on medical testimony linking the onset of symptoms to that event rather than pre-existing conditions. It awarded $48,552.53 against Aucoin after applying the Leger rule to limit recovery to 75% of the plaintiff's total collision-related damages in light of the settlements, while declining to reduce damages for the plaintiff's reasonable refusal of surgery.

torts & liabilityprocedure