Ranger

Opinion of the Court by Evans, J.

In general, those who are injured while on board a vessel in navigable waters because of the negligence of their employer or the vessel owner may have a cause of action under a federal statute, judge-made general maritime law, or both. (See 1 Schoenbaum, Admiralty and Federalism (6th ed. Nov. 2023 update) §§ 4:1, 5:4.) In this case, plaintiff Brian Ranger (Ranger) seeks damages under general maritime law for injuries he alleges were caused by the negligence of his vessel-owning employer, defendant Alamitos Bay Yacht Club (the Club). The Club argues that Ranger is barred from asserting these federal common law claims because he does not qualify as a statutory “employee” within the meaning of the Longshore and Harbor Workers’ Compensation Act (LHWCA; 33 U.S.C. § 901 et seq.). The LHWCA, as amended in 1984, excludes from the federal workers’ compensation scheme individuals who (like Ranger) are employed by “a club” and “are subject to coverage under a State workers’ compensation law.” (33 U.S.C. § 902(3)(B).) The Court of Appeal agreed with the Club and affirmed the order sustaining the Club’s demurrer to Ranger’s complaint without leave to amend.…