Maritime workers injured at sea may seek compensation under the Jones Act—but only if they qualify as “seamen” under federal law. That definition, though seemingly simple, has been the subject of decades of litigation. In Chandris, Inc. v. Latsis, 515 U.S. 347 (1995), the U.S. Supreme Court attempted to clarify the standard for seaman status. While the decision resolved some longstanding circuit splits, it also introduced ambiguity into the maritime legal landscape.
The Jones Act provides maritime workers the right to sue employers for negligence—but only if they are classified as “seamen.” Before Chandris, courts differed on what level of connection to a vessel was required. Some followed the Fifth Circuit’s more inclusive “Robison” test, while others aligned with the Seventh Circuit’s narrower “Johnson” standard.
In Chandris v. Latsis, the Supreme Court held that to qualify as a seaman, a maritime worker must:
This decision built upon the 1991 case McDermott International, Inc. v. Wilander, where the Court eliminated the requirement that a seaman must “aid in navigation.” Chandris extended the analysis by emphasizing the importance of a worker’s enduring relationship to a vessel.
One of the key outcomes of Chandris was the Supreme Court’s endorsement of a “30% rule”—a practical guideline used by lower courts. A maritime worker must spend at least 30% of their work time aboard a vessel in navigation to qualify as a seaman. This effectively disqualified land-based employees with only occasional vessel duties.
This was a departure from the Second Circuit’s ruling, which allowed seaman status based on either the nature or duration of the connection. The Supreme Court, however, required that the connection be substantial in both respects.
The plaintiff in Chandris, Spyridon Latsis, was a ship engineer employed in a supervisory role who traveled to vessels intermittently. He was injured during an extended assignment aboard the Galileo, yet the Court found he did not meet the temporal requirements for seaman status. His time spent aboard the vessel during a renovation period in drydock was excluded because the vessel was not “in navigation.”
The Court reasoned that granting seaman status to transient workers would undermine predictability for maritime employers. Yet critics, including Justice Stevens in his concurrence, argued that workers injured during extended sea voyages should be presumed to qualify as seamen when exposed to “the perils of the sea.”
Maritime law scholars and advocates argue that Chandris may exclude workers the Jones Act was designed to protect. Traditionally, seamen were seen as “wards of admiralty” who faced unique dangers, such as medical delays and exposure to the elements. But the Chandris test’s emphasis on measurable time aboard vessels may overlook the realities of workers like Latsis, who performed critical shipboard functions but had land-based job titles.
While the decision aimed to reduce employer uncertainty and litigation costs, it may also limit recovery options for injured workers in hybrid or rotating positions—those who perform duties both on land and at sea.
After Chandris, courts conduct a fact-intensive inquiry into both the nature of a worker’s duties and how much time they spend aboard vessels in navigation. The test focuses on the entire duration of employment with a particular employer, not just isolated assignments.
This has significant implications for cruise industry employees, offshore oil workers, and port-based personnel who may occasionally travel with a vessel. If they spend less than 30% of their time aboard, they likely will not qualify for Jones Act protections—even if injured during a voyage.
If you’re a maritime worker injured at sea or during vessel operations, it’s crucial to understand whether you qualify as a Jones Act seaman. The legal standard is complex and evolving. Courts apply a case-by-case approach based on how much time you spend aboard a navigable vessel and whether your job contributes to its function or mission.
Our experienced maritime attorneys can help assess your eligibility and fight for your rights under the Jones Act, general maritime law, or other available remedies.
Contact us now to discuss your seaman status and injury claim.
Disclaimer: Our firm does not represent the parties in this case and is not involved in the litigation. The information provided is a summary of legal principles based on publicly available sources. We make no representations about the truth of the underlying events, and we are not predicting any outcome.