The Alamitos Bay Yacht Club in Long Beach hired Brian Ranger as a maintenance worker. He helped the club with its fleet by painting, cleaning, maintaining, repairing, unloading, and mooring vessels.

One day, Ranger used a hoist to lower a club boat into navigable waters. He stepped from the dock onto its bow, fell, was hurt, and applied for workers’ compensation. Then he sued the club in state court on federal claims of negligence and unseaworthiness.

The trial court sustained the club’s final demurrer to the second amended complaint. The trial court ruled there was no admiralty jurisdiction.

The California Court of Appeal affirmed the trial court decision to dismiss the case in the published case of Ranger v. Alamitos Bay Yacht Club – 95 Cal. App. 5th 240, 313 Cal. Rptr. 3d (September 2023). The opinion concluded that “In sum, California’s workers’ compensation law is Ranger’s exclusive remedy. Congress in 1984 decreed this state law aptly covers his situation. A core part of the state workers’ compensation bargain is that injured workers get speedy and predictable relief irrespective of fault. In return, workers are barred from suing their employers in tort. The trial court correctly dismissed Ranger’s tort suit against his employer.”

The California Supreme Court reversed in Ranger II v. Alamitos Bay Yacht Club 17 Cal.5th 532 (February 2025). It ruled the Longshore Act’s exclusion of club workers from the act’s coverage meant only that the state, rather than the federal, workers’ compensation system applies, but did not otherwise deprive workers of their federal right to pursue available tort remedies under general maritime law. (Ranger, supra, 17 Cal.5th at p. 548.)

The state’s top court wrote “To the extent the Court of Appeal’s opinion suggests that California’s workers’ compensation scheme in itself displaces general maritime remedies and constitutes Ranger’s exclusive remedy, we disagree. It is true that California’s workers’ compensation system provides ‘a comprehensive statutory scheme governing compensation given to California employees for injuries incurred in the course and scope of their employment.” (Charles J. Vacanti, M.D., Inc. v. State Comp. Ins. Fund (2001) 24 Cal.4th 800, 810 [102 Cal.Rptr.2d 562, 14 P.3d 234].) Under Labor Code section 3602, the workers’ compensation remedy “provides an injured employee’s “exclusive” remedy against an employer for compensable work-related injuries.’ (King, supra, 5 Cal.5th at p. 1046.) We conclude, though, that the exclusive-remedy provision does not displace federal law in this case.”

The California Supreme Court remanded the case to back to the Court of Appeal to consider: 1) whether federal jurisdiction exists; 2) whether Ranger can assert the tort of unseaworthiness; and 3) whether Ranger can assert a negligence claim against his vessel- owning employer.

On remand the California Court of Appeal in the unpublished case of Ranger III v. Alamitos Bay Yacht Club -B315302 (September 2025) answered these three questions.

In answering the first question, the Court of Appeal began with the step analysis in Grubart v. Great Lakes Dredge & Dock Co. (1995) 513 U.S. 527 and reviewed and applied case law following that decision and held that admiralty jurisdiction applies to Ranger’s claim.

The review next turned to the Club’s contention that, even if Ranger’s claim is within admiralty jurisdiction, he cannot bring a claim for unseaworthiness because this claim can only be brought by Jones Act seamen. After reviewing case law beginning with Seas Shipping Co. v. Sieracki, (1946) 328 U.S. 85 and following, the Court of Appeal ruled that this “argument is incorrect. Ranger has an unseaworthiness claim.”

The Court of Appeal then moved to the third question. “We turn finally to the Club’s faulty contention that Ranger cannot bring a claim against it for negligence as a vessel owner because it is also his employer.” The Club’s argument fails because it is founded in the Longshore Act, which does not cover Ranger.”

“The fact that the Longshore Act only prohibits workers engaged in certain types of service to the vessel from bringing a negligence claim suggests that even covered workers not engaged in those services can sometimes appropriately sue the vessel owner for negligence. The Club has not established Ranger cannot sue the Club for negligence as the vessel owner.”