Quentin Hedrick v. Daiko Shoji Co., Ltd., Osaka, and Pine Oak Shipping, S.A.

Quentin Hedrick, a longshoreman injured on the job, appeals a judgment n.o.v. in favor of the defendant ship, and a judgment dismissing his claim for want of jurisdiction against the foreign manufacturer of a defective wire-rope splice that gave way and caused his injury.

The judgment n.o.v. in favor of the ship raises important questions about the residual liability of the ship for its own negligence following the 1972 revisions of the Longshoremen’s and Harbor Workers’ Compensation Act, 33 U.S.C. §§ 901 , et seq. The dismissal for want of jurisdiction requires a close examination of World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 , 100 S.Ct. 559 , 62 L.Ed.2d 490 (1980) and Raffaele v. Compagnie Generale Maritime, 707 F.2d 395 (9th Cir.1983).

Hedrick was severely and permanently injured when a defective splice in a wire rope pulled loose, allowing a ship’s boom to sweep out of control and hit him. The splice was manufactured by Daiko Shoji Co., Ltd. of Osaka, Japan (“Daiko”). Hedrick was working aboard the Cressida, owned and operated by Pine Oak Shipping, S.A., a Japanese corporation.

The defective splice formed the eye of a vang pendant, a steel cable on which was…