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James Reeves v. B & S Welding, Inc., and Exxon Corporation
Citations: 897 F.2d 178; 1990 U.S. App. LEXIS 4273; 1990 WL 21313Docket: 88-3831
Court: Court of Appeals for the Fifth Circuit; March 26, 1990; Federal Appellate Court
James Reeves, the plaintiff-appellant, sustained injuries while working on an offshore gas production platform operated by Exxon Corporation and maintained by B. S Welding, Inc. The incident occurred on platform 342-B in the High Island Field of the Gulf of Mexico during a repair operation, where Reeves and his crew were replacing handrails. The accident happened when a detached handrail became entangled with an emergency shut-down line, causing Reeves to stumble and subsequently injure his foot when the handrail landed on it. Reeves filed suit against Exxon and B. S Welding, asserting claims under the Jones Act and General Maritime Law. The district court dismissed the Jones Act claim against B. S, ruling Reeves did not qualify as a seaman, and later ruled in favor of Exxon in the indemnity claim against B. S. The court concluded that Texas law was applicable based on the Outer Continental Shelf Lands Act (OCSLA), which defines the jurisdictional boundaries for legal claims involving adjacent states. Reeves appealed the judgment, while B. S Welding did not. The district court determined that Platform 342-B is "adjacent" to Texas, a conclusion the appellant contests, asserting the platform is adjacent to Louisiana, which would allow for a claim under Louisiana's "ruin" statute. This statute holds building owners liable for damage due to "ruin" from construction defects or maintenance failures. Evidence presented showed Platform 342-B is closer to the Texas coast, supported by charts from Exxon and federal agencies indicating its adjacency to Texas rather than Louisiana. Previous court rulings have similarly classified platforms in the High Island Field as adjacent to Texas under the Outer Continental Shelf Lands Act (OCSLA). The boundary between Texas and Louisiana extends south-southeast into the Gulf, with Louisiana's waters extending three miles and Texas’ three marine leagues (approximately ten miles). The appellant proposed that if certain north/south lines were drawn, Platform 342-B would fall within Louisiana waters. However, Exxon's counterarguments, based on the existing boundary line, placed the platform within Texas waters. The appellant's proposals lacked sufficient evidence, while Exxon's were consistent with the established boundary. The court concluded that the evidence confirmed Platform 342-B is closer to Texas and recognized by federal agencies as off the Texas coast. Thus, the district court's determination that the platform is adjacent to Texas under the OCSLA was upheld. Additionally, the appellant claimed twenty-six of the district court's thirty-nine findings of fact were erroneous; however, after reviewing the record, the court found these claims were based on conflicting evidence. It affirmed that the district court's findings were not clearly erroneous. The ruling was therefore affirmed.