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Keywords

negligencetestimony
damagesnegligencetrialtestimony

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Salem v. United States Lines Co.

Facts

Petitioner was a lookout on the S. S. United States and was injured while moving from a ladder to a platform leading to his post in the crow's-nest. The crow's-nest was housed in a hollow aluminum radar tower that rose 65 feet from the bridge deck. The platform had a narrow ledge and lacked safety devices to assist the seaman in maneuvering from the ladder to the platform. On the night of the accident, the tower was plunged into darkness, and as petitioner attempted to move to the platform, he fell backwards and was injured.

Petitioner was a lookout on the S. S. United States. He was injured as he moved from a ladder to a platform leading to his post in the crow's-nest. The crow's-nest was housed in a 'bubble' half way up a hollow aluminum radar tower which rose 65 feet from the bridge deck. The ladder extended the full height of the tower along the inside of its after side. At various levels inside the tower were horizontal platforms, at the after ends of which were access openings slightly larger than manholes, through which the ladder passed straight up.

Issue

Whether the jury should have been allowed to determine, in the absence of supporting testimony by an expert in naval architecture, a claim that the shipowner failed to equip his ship with necessary and feasible safety devices.

The first question to be decided in this seaman's personal injury suit for damages on the grounds of unseaworthiness and negligence under the Jones Act is whether the jury should have been allowed to determine, in the absence of supporting testimony by an expert in naval architecture, a claim that the shipowner failed to equip his ship with necessary and feasible safety devices to prevent the mishap which befell the seaman.

Rule

Expert testimony is not always required in actions of unseaworthiness or negligence under the Jones Act; a jury may decide on issues of safety if the potential danger is obvious and the primary facts can be accurately described.

This is not one of the rare causes of action in which the law predicates recovery upon expert testimony. Rather, the general rule is as stated by Mr. Justice Van Devanter, when circuit judge, that expert testimony not only is unnecessary but indeed may properly be excluded in the discretion of the trial judge 'if all the primary facts can be accurately and intelligibly described to the jury, and if they, as men of common understanding, are as capable of comprehending the primary facts and of drawing correct conclusions from them as are witnesses possessed of special or peculiar training, experience, or observation in respect of the subject under investigation . . . .'

Analysis

The court found that the jury was competent to determine whether the safety devices provided were sufficient to discharge the shipowner's duty to provide a safe working environment. The court emphasized that the potential danger was obvious, and thus, expert testimony was not necessary for the jury to make an informed decision.

The court found that the jury was competent to determine whether the safety devices provided were sufficient to discharge the shipowner's duty to provide a safe working environment. The court emphasized that the potential danger was obvious, and thus, expert testimony was not necessary for the jury to make an informed decision.

Conclusion

The Supreme Court reversed the circuit court's order, holding that expert testimony was not always required in actions of unseaworthiness or negligence under the Jones Act. The court affirmed the circuit court's holding that the jury's maintenance award was unsupported by evidence in the record.

The court reversed the circuit court's order and held that expert testimony was not always required in actions of unseaworthiness or negligence under the Jones Act. Only when the issues were so complex that people of common understanding could not grasp them would expert testimony be required.

Who won?

Petitioner prevailed in the case because the Supreme Court ruled that the jury should have been allowed to consider the shipowner's failure to provide safety devices without the necessity of expert testimony.

Petitioner prevailed in the case because the Supreme Court ruled that the jury should have been allowed to consider the shipowner's failure to provide safety devices without the necessity of expert testimony.

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