In January 2018, the Fifth Circuit in In Re: In the Matter of the Complaint of Larry Doiron, Incorporated set aside the “confusing,” six-factor, fact-intensive test of maritime contract jurisdiction from Davis & Sons, in favor of the conceptual two-factor test laid out in Norfolk Southern Railway Co. v. Kirby.

In January 2018, the Ninth Circuit in Batterton v. Dutra Group affirmed the lower court’s decision ruling that punitive damages are awardable to seamen in unseaworthiness actions. The Court relied on its 1987 decision in Evich v. Morris, where it “squarely held that ‘[p]unitive damages are available under general maritime law for claims of unseaworthiness’” and found that the U.S.

In June 2015, an employee of Modern American Recycling Service (MARS) was killed when he stepped through an unmarked open hole on a platform. The hole was created by Manson Gulf, LLC during its decommissioning process of the platform.