Causation is a Finding of Fact in Admiralty Bench Trials

Causation is a Finding of Fact in Admiralty Bench Trials 

By: Jamie Johnson

In a bench trial, a district court’s determination of causation is a finding of fact that will rarely be set-aside on appeal. in Hale v. Omega Protein, Inc.,Employee, Derek Hale, brought an action in Eastern District of Louisiana against his employer, Omega Protein, alleging liability for injuries resulting from a piece of debris that fell onto his forearm. Hale claimed that the incident also caused knee, shoulder, neck, and back problems. After a bench trial, the EDLA ordered Omega to pay Hale for medical care related only to the forearm injury. The court held that the other injuries were not caused by debris landing onto Hale’s forearm, thus precluding damages for any other injuries asserted by Hale.The appeals court affirmed the district court’s opinion noting the following evidence on the record: First, the sole complaint by Hale on the day of the accident came from his arm and elbow. Second, in follow up medical visits Hale only mentioned pain in his right arm. Finally, Hale’s physician noted that his back pain was unrelated to the forearm injury, and evidence showed that he had bulging discs in his spine both before and after the accident.Thus, the court found that the evidence failed to support a causal link between the fishing accident and later reported injuries for neck, back, and shoulder pain.