Isle of Capri Casino v. Wilson

776 N.W.2d 112 (2009)

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Isle of Capri Casino v. Wilson

Iowa Court of Appeals
776 N.W.2d 112 (2009)

Facts

Diane Wilson (defendant) worked as a housekeeper for the Isle of Capri Casino (the casino) (plaintiff), which was a riverboat casino and hotel on the Mississippi River. The casino regularly sailed until 2004 because Iowa law had required casino riverboats to sail 200 hours per year. However, Iowa removed the 200-hour requirement in June 2004, and the casino elected to stop sailing. Nevertheless, the casino retained a captain and marine crew on staff, had insurance coverage certifying it to sail, and could sail within 90 minutes at any given time. In January 2005, Wilson was injured at work. Wilson sought workers’-compensation benefits, but the casino denied Wilson’s claim. The casino asserted that the Iowa Workers’ Compensation Commission (the commission) lacked jurisdiction over Wilson’s claim because the claim was governed by the federal Jones Act. The Jones Act provided that seamen injured in the course of their employment could sue their employers to recover for their injuries. The Iowa Supreme Court had previously held that if an employee qualified as a seaman under the Jones Act, the commission did not have subject-matter jurisdiction to award benefits. An employee acquired seaman status if (1) the employee’s duties contributed to the function or mission of the vessel, and (2) the employee had a substantial connection to a vessel in navigation. Wilson agreed that her work at the casino contributed to the casino’s function and mission. However, Wilson asserted that the casino was not a vessel in navigation because the casino had elected to stop sailing. A deputy commissioner concluded that the commission had jurisdiction over Wilson’s workers’-compensation claim and awarded benefits. The commission adopted and affirmed the decision, and the casino sought judicial review in Iowa state court. On review, the trial court found that the commission had improperly determined that it had jurisdiction over Wilson’s claim. The court reasoned that the casino was still capable of sailing at the time of Wilson’s injury and had not been permanently moored until November 2005. Wilson appealed to the Iowa Court of Appeals.

Rule of Law

Issue

Holding and Reasoning (Sackett, C.J.)

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