When Form Meets Substance: Two Fifth Circuit Decisions Chart the Boundary Lines of Summary Judgment

Baker Donelson

Baker Donelson

Murky waters swirl in the legal gulf that separates the absence of any “genuine dispute[s] as to any material fact” (in which case summary judgment is appropriate); and the presence of non-speculative “evidence [on which] a reasonable jury could return a verdict for the nonmoving party” (in which case summary judgment is not appropriate and the case must be fully tried to the fact finder). Two recent Fifth Circuit decisions, however, have plumbed these depths and charted a truer course (if only slightly) for navigating maritime summary judgments – although the two decisions resulted in diametrically opposed outcomes.

Jones v. United States

First, Jones v. United States, 2019 WL 4050462 (5th Cir. 8/28/19); — F. 3d — (which the Court has designated for publication) involved claims for Jones Act negligence and general maritime law unseaworthiness/maintenance and cure by a seaman who allegedly injured his arm when he slipped and fell on the U.S. government-owned vessel M/V CAPE KNOX. The CAPE KNOX (moored in the Mississippi River at the mouth of the Industrial Canal in New Orleans), is one of the U.S.’s strategic sealift “Ready Reserve Fleet” of merchant vessels, owned by the government and operated by Keystone Shipping Company, and manned with a skeleton crew to maintain the vessels in working order and preparedness for mobilization in the event national defense/security so requires.

Jones claimed that during his night rounds, as he was lifting his left foot over a nine-inch coaming while entering the diesel generator room, his right foot slipped on grease. However, Jones testified that he did not actually see any grease (although he had a flashlight) and the incident report he completed immediately afterwards did not mention grease at all. Jones claimed the grease would have come from the cables located above the weather deck, which are greased regularly resulting in grease dropping onto the weather decks and then being tracked into the generator room. The district court, sitting as the non-jury trier of fact in an admiralty claim against the U.S. (pursuant to 46 U.S.C. § 30903(b)) granted summary judgment and dismissed Jones’ claim, notwithstanding the “featherweight” causation standard for Jones Act negligence claims (which provides that a Jones Act negligence claimant can prove causation if he can show that “employer negligence played any part, even the slightest, in producing the injury,” 2019 WL 4050462, *2).

The Fifth Circuit affirmed and did so by clarifying/reaffirming two important procedural points for summary judgment practice in a Jones Act claim.

First, after setting out the well-known summary judgment standard (i.e., no genuine dispute as to any material fact, non-movant must present actual evidence to show a genuine dispute and cannot rely on speculation, improbable inferences, or unsubstantiated assertions), the Fifth Circuit reaffirmed a critically important procedural aspect of summary judgment practice in non-jury bench tried cases (which includes many types of admiralty cases):

We have held that [i]n a non-jury case, such as this one, a district court has somewhat greater discretion to consider what weight it will accord the evidence. When deciding a motion for summary judgment prior to a bench trial, the district court has the limited discretion to decide that the same evidence, presented to him or her as a trier of fact in a plenary trial, could not possibly lead to a different result.

2019 WL 4050462, at *2. In other words, when the same judge/fact-finder considering the summary judgment record would be considering the same facts/evidence/testimony at trial, it makes practical, efficient sense for the judge to be able to draw inferences/make “judgment calls” that would technically be left to the jury if the case were to be jury tried. The only exception to this broader discretion for summary judgment in a bench-tried case is that the judge cannot draw inferences that involve issues of witness credibility or disputed material facts. See In re Placid Oil Co., 932 F.2d 394, 398 (5th Cir. 1991).

Jones argued that his testimony asserting that there was “grease in many places on the ship’s deck” was sufficient to avoid summary judgment, and that the trial court’s rejection of that testimony was essentially a prohibited credibility determination. Further, Jones contended that the trial court made de facto credibility determinations when it accepted the U.S.’s affidavits (indicating there was no grease present) over Jones’ expert affidavit.

The Fifth Circuit, however, rejected this argument because grease somewhere on the vessel did not provide specific evidence of grease in the location of the incident:

[S]peculation cannot defeat summary judgment on a required element of the claim. We of course follow the Supreme Court’s instruction that “entirely circumstantial” evidence can prove a Jones Act claim. But grease elsewhere on the ship’s deck at various times is not “probative” circumstantial evidence that can withstand summary judgment. If Jones returned to the hatch that night or the next morning and saw grease where he slipped, things might be different. But Jones never saw grease in the spot where he slipped, even when he later investigated his fall. As we [have] explained in [other Jones Act jurisprudence] “[t]he path from worker injury to employer liability.” Evidence that other parts of the ship were slippery at other times does not do so.

Moreover, Jones’ expert’s only basis for the presence of grease was Jones’ own inconclusive testimony about grease elsewhere on the vessel; and thus, his unsubstantiated, conclusory opinion was not a fact that could defeated summary judgment.

Jones also argued that the trial court’s decision effectively creates a rule requiring a personal injury plaintiff to immediately investigate the circumstances of his accident, which is unfair. The Fifth Circuit rejected this as well, noting that the trial court “did not fault Jones’s investigation or lack thereof but simply held that no summary-judgment evidence, however it might have been developed, reached the fact of whether Jones slipped on grease.” Id. at *3.

In short, in venerable admiralty Judge John R. Brown’s words, there must be evidence of causative fault, “not merely fault in the abstract.” Bd. of Comm’rs of Port of New Orleans v. M/V Farmsum, 574 F.2d 289, 297 (5th Cir. 1978).

Second, the Fifth Circuit rejected Jones’ argument that the trial court’s ruling violated the “featherweight” causation standard for Jones Act negligence on similar grounds: “The causation standard for Jones Act negligence is “slight[ ],” well below the common-law standard… [b]ut it is not no standard at all. Id. This is an important, strong confirmation that while Jones Act negligence does require a lower standard of causation, it is not a foregone conclusion in every case, and a plaintiff should be required present some positive evidence of causation to defeat summary judgment.

Finally, as to Jones’ unseaworthiness claim, the Fifth Circuit confirmed the intuitive result that because he was unable to “show [causation] under the lighter Jones Act standard” he likewise could not do so for his unseaworthiness claim (even though a greasy deck would be an unseaworthy condition), because that claim requires the heightened showing of “proximate causation.” Id. at *4. In other words, if he could not meet the featherweight standard for Jones Act negligence, he could not meet the more demanding “proximate cause” standard for unseaworthiness.

Thus, the two important takeaways from the Jones decision are (1) the judge in a bench-tried matter has more discretion to grant summary judgment evidence on the record before the court; and (2) Jones Act negligence requires some evidence of causation, notwithstanding the “featherweight” standard of proof. And while the Jones decision was in the Jones Act negligence context, these same principles should apply in any bench-tried admiralty case.

Manson Gulf, L.L.C. v. Lafleur

On the polar opposite end of the summary judgment spectrum, the Fifth Circuit in Manson Gulf, L.L.C. v. Lafleur, 2019 WL 4124431 (5th Cir. 8/29/19) (unpublished, per curiam) affirmed the trial judge’s post-trial ruling – which came after a prior Fifth Circuit reversal of the same trial judge’s grant of summary judgment (see Manson Gulf, L.L.C v. Modern Am. Recycling Serv., Inc., 878 F.3d 130, 133 (5th Cir. 2017)) – in a wrongful death action arising from an offshore worker’s fall through a hole in the grating of an offshore platform that was being deconstructed.

By way of background, the Fifth Circuit’s earlier summary judgment reversal was previously reported on this blog, and had been based on the “open and obvious” doctrine. Specifically, the district court had previously held as a matter of undisputed fact and law that the vessel owner servicing the deconstruction project had no duty/liability under the Scinida “turnover duty” framework, detailed in our prior blog post. Specifically, the district court ruled that the open hole in the platform was “open and obvious” because the platform was in the process of being taken part, and because the missing grating/hole was (or should have been) “open and obvious” to a reasonably competent stevedore/offshore worker engaged in a platform deconstruction. This was despite the fact that witnesses confirmed that these types of open holes in platform grating are typically marked during deconstruction operations.

However, the Fifth Circuit reversed summary judgment – even though the case was being tried to the bench, thus affording the trial judge more discretion to weigh the evidence and draw inferences – specifically (1) because there was conflicting testimony – and thus credibility issues to be considered – from the lone witness to the accident about whether/how the hole in the grating was obvious; and (2) based on color photographs of the site/hole in question, which the Court used to support its determination that the evidence was in conflict, thus precluding summary judgment.

With this background, the intuitive presumption would be that the same trial judge who had summarily dismissed the case on summary judgment under the “open and obvious” doctrine would have been very unlikely to be swayed to a different conclusion – or would at least find substantial comparative fault on the part of the plaintiff. However, in the Fifth Circuit’s more recent treatment of Manson, the precise opposite happened. After reversal of summary judgment and remand, the case was sent back down to the trial court for a full trial on the merits, and somewhat surprisingly, the trial judge found for the plaintiff – with  zero percent comparative fault – effectively reversing his prior determination on “open and obviousness” and awarding over $4.2 million in damages. The district court’s post-trial liability ruling focused on witness testimony regarding Manson’s failure to mark the hole as per standard industry practice (a factor it had previously minimized in its reversed summary judgment ruling).

On appeal, Manson argued that the district court erred in excluding its expert testimony regarding the hazards to be expected during platform scrapping. Notably, the district court did not assign reasons for the exclusion of this expert, but the context indicates he was stricken on the premise that his testimony would not be helpful to the court as finder of fact precisely because the question was whether the hole in the grating was “open and obvious” (which cannot, as a practical matter, be informed by any expert testimony). The Fifth Circuit rejected this argument outright under “highly deferential” standard of review for a trial court’s discretion to admit/exclude experts – which is even higher in a bench-tried case.

Likewise, the court rejected all Manson’s other arguments on liability, essentially on the highly deferential standard of review for the trial court’s findings of fact. The only issue on which Manson prevailed was the reversal of prejudgment interest on future damages (under the Fifth Circuit’s well-established rule that “prejudgment interest may not be awarded for future damages in admiralty cases,” 2019 WL 4124431 at *3.

The dramatic difference in outcome in Manson – from a  no money/zero percent liability summary judgment dismissal, to a $4.2 million 100 percent liability verdict – demonstrates in real commercial terms the very thin boundary line separating the gulf between “no genuine dispute as to any material fact” and credibility issues/disputed evidence sufficient to prove liability.

Juxtaposing Jones with Manson gives litigants not only a good framework for the mechanics/procedure of how to successfully prosecute/defend against summary judgment, but also a stark and tangible example of how fine the line between form and substance, victory and defeat, can be.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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