Trahan v. Teleflex, Inc.

Randy Trahan (plaintiff) was riding as a passenger in his 17-foot boat on English Bayou. The steering cable on the boat broke, causing the boat to make a sudden, sharp turn. Trahan was thrown from the boat and injured. Trahan sued Teleflex, Inc. (defendant), the manufacturer of the steering cable, under maritime products liability and general maritime law. In Louisiana, bringing a maritime tort action required both that the tort occurred on navigable waters and that the tort bore a significant connection to a traditional maritime activity. Teleflex filed an exception for lack of subject-matter jurisdiction, claiming that English Bayou was not a navigable body of water at the location of the accident. Evidence was provided that commerce did not frequently occur on that section of the bayou but that it had been used for commerce in the past and that it was possible to travel by boat from the location of the accident in the bayou all the way to the Gulf of Mexico. The trial court held that English Bayou in the area of the accident was in fact navigable. As a result, the court denied Teleflex’s exception for lack of subject-matter jurisdiction and granted Trahan’s motion for partial summary judgment as to the navigability of the bayou. Teleflex appealed, alleging that the bayou was not navigable and that the trial court therefore erred in denying its exception and granting Trahan’s partial summary judgment.