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Keywords

lawsuitnegligenceappealtrialbench trial
appealtrial

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Sana v. Hawaiian Cruises, Ltd., 181 F.3d 1041, 1999 A.M.C. 1831, 52 Fed. R. Evid. Serv. 600, 99 Cal. Daily Op. Serv. 4294, 1999 Daily Journal D.A.R. 5465

Facts

Peter Sana was hired by Hawaiian Cruises to work in the galley of the Navatek I. After working normal shifts on March 9 and 10, 1995, he exhibited unusual behavior and symptoms, leading to a diagnosis of viral encephalitis. Despite his family's concerns and medical evaluations, the cause of his illness remained undetermined, and Hawaiian Cruises denied his request for maintenance and cure. Sana subsequently filed a lawsuit, which led to a bench trial where the court ruled against him.

On January 5, 1995, Hawaiian Cruises hired Sana to work in the galley aboard the Navatek I, a vessel used for whale-watching cruises.

Issue

Did the district court err in excluding the investigator's report as evidence and in concluding that Sana was not entitled to maintenance and cure under the Jones Act?

Did the district court err in excluding the investigator's report as evidence and in concluding that Sana was not entitled to maintenance and cure under the Jones Act?

Rule

A seaman who falls ill while in the service of his vessel is entitled to maintenance and cure, regardless of the shipowner's negligence or fault. The obligation is traditionally construed liberally.

A seaman who falls ill while in the service of his vessel is entitled to … maintenance and cure.

Analysis

The court found that the exclusion of the Rutherford report, which contained statements from Sana's co-workers about his condition, was an abuse of discretion. This report could have supported Sana's claim that he exhibited symptoms of encephalitis while working. The court also noted that the traditional liberality of the maintenance and cure remedy should have favored the admission of this evidence.

The court found that the exclusion of the Rutherford report, which contained statements from Sana's co-workers about his condition, was an abuse of discretion.

Conclusion

The Court of Appeals reversed the district court's decision and remanded the case for a new trial, stating that the exclusion of the Rutherford report materially affected the outcome.

The Court of Appeals reversed the district court's decision and remanded the case for a new trial.

Who won?

Hawaiian Cruises initially prevailed in the district court, but the Court of Appeals reversed this decision, indicating that the exclusion of evidence was a significant error.

Hawaiian Cruises initially prevailed in the district court, but the Court of Appeals reversed this decision.

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