Personal Jurisdiction Over a Foreign Ship Manager: A Claim-By-Claim Analysis

NOTE: This post was co-authored by William L. Pardue, a Loyola University New Orleans College of Law student who is spending part of his summer working at King & Jurgens.  Carmona v. Leo Ship Mgmt, Inc.; No. 18-20248, 2019 WL 2067296* (5th Cir. May 10, 2019). This Fifth Circuit decision addressing a court’s personal jurisdiction over a foreign company proceeds from the U.S. District Court for the Southern District of Texas. In 2014, Jose Carmona, a longshoreman, was injured when a bundle of pipes he was rigging for discharge from the hold of a vessel broke free and fell, injuring his ankle and lower leg. Carmona sued the ship’s manager, Leon Ship Management (“LSM”), in state court in Houston pursuant to 33 USC 905(b) of the Longshore and Harbor Workers’ Compensation Act, alleging that LSM breached its duty to: (1) properly stow the pipes; (2) minimize hazards associated with falling pipes; (3) take precautions to protect workers; (4)…

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