Fields v. Pool Offshore, Inc.’s Empirical Analysis
182 F.3d 353 · 1999
Citation profile
12 federal appellate · 3 district ·
How this case has been cited
Cited by 51 later decisions — most recently March 2024 · most notably Smallwood v. Illinois Central Railroad (2004), Carrie Badon
12 federal appellate · 3 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Rodrigue v. Aetna Casualty & Surety Co. · Chandris, Inc. v. Latsis · Harbor Tug and Barge Company v. Papai · Cope v. Vallette Dry Dock Co. · Cook v. Belden Concrete Products, Inc.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Courts have long recognized a distinction between “work platforms” that are designed for primarily stationary residence and true vessels. Looking to the language of the statute, we have consistently defined vessel status in reference to the importance of transportation as the craft’s purpose. In particular, we have focused on three factors when trying to determine whether a structure is a work platform beyond the realm of the Jones Act. First, we ask whether the structure was constructed to serve primarily as a work platform. Second, we look to whether or not the structure was moored or otherwise secured at the time of the accident. Lastly, we attempt to ascertain whether the transportation function of the structure went beyond theoretical mobility and occasional incidental movement. In applying the three-factor test of work-platform status to the Neptune Spar, it becomes apparent that it cannot be a vessel. As the defendants’ affidavits indicated, there are no plans to even consider moving the Neptune Spar until the current field is exhausted. While nothing can ever be certain in the petroleum industry, the unchallenged prediction of defendants is that the field will remain productive for the next fifteen years. This distinguishes the Neptune Spar from the types of specialized mobile drilling craft that we have previously classified as vessels. As we have taken care to point out, while such drilling craft may stay on a particular site, they always move on to the next locatio”
3 later decisions quote this exact passage · from the majority“[a] spar is a nautical structure designed to float with the bulk of the hull below waves — something akin to a giant buoy,” and spars have increasingly been used”
2 later decisions quote this exact passage · from the majority“the district court is authorized 'to use a summary judgment-like procedure for disposing of fraudulent pleading claims'”
2 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.