Cruise Ship Law

HARVEY'S CASINO, Appellant, vs. BEVERLY ISENHOUR, Appellee. AMERISTAR CASINOS COUNCIL BLUFFS, INC. and GAB ROBINS, Appellants, vs. AMANDA A. DAVIS, Appellee. AMERISTAR CASINOS COUNCIL BLUFFS, INC. and GAB ROBINS, Appellants, vs. HELEN FALANGA, Appellee.
SUPREME COURT OF IOWA
724 N.W.2d 705; 2006 Iowa Sup. LEXIS 162
December 8, 2006, Filed

PROCEDURAL POSTURE: Appellee claimants challenged a decision from the Iowa Court of Appeals, which reversed a district court's decision that the Iowa Workers' Compensation Commission had jurisdiction to order benefits paid by appellant employers.

OVERVIEW: The claimants worked on casino riverboats, and they filed workers' compensation claims after they suffered work-related injuries. The Commission ruled that it had subject matter jurisdiction to award benefits, and the district court agreed. The court of appeals reversed, and this appeal followed. In affirming the court of appeals, the supreme court determined that the claimants were not covered by Iowa workers' compensation law because they were covered by a compensation statute enacted by Congress, pursuant to Iowa Code § 85.1(6). The claimants were covered by 46 U.S.C.S. § 688a. The claimants fit the definition of "seaman" because they had a substantial connection to the vessel and they contributed to the accomplishment of the vessel's missions, which was gambling. Further, the definition of vessel under 1 U.S.C.S. § 3 only required that a watercraft be used or capable of use as a means of water transportation; it did not have to be used primarily for that purpose. The boats in question were used in river waters about 200 hours per year.

OUTCOME: The decision of the court of appeals was affirmed. The district court's decision was reversed, and the case was remanded for dismissal of the workers' compensation claims.