California Supreme Court Watch

#23-260 Ranger v. Alamitos Bay Yacht Club, S282264. (B315302; 95 Cal.App.5th 240; Los Angeles County Superior Court; 19STCV22806.) Petition for review after the Court of Appeal affirmed the judgment in a civil action. This case presents the following issue: May a maritime worker described by 33 United States Code section 902(3)(A)–(F) within the Longshore and Harbor Workers’ Compensation Act (33 U.S.C. § 901 et seq.) bring an action to recover for a workplace injury under the general maritime law or does California’s workers’ compensation scheme provide the worker’s exclusive remedy?

Petition for review granted: 12/20/2023

Case fully briefed: 4/22/2024

Cause argued and submitted: 12/04/2024

Opinion filed: Judgment reversed: 2/27/2025

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

See the California Supreme Court Opinion.  (Ranger v. Alamitos Bay Yacht Club (2025) 17 Cal.5th 532.)

“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.

We conclude the Court of Appeal erred. The 1984 amendments to the LHWCA specify which workers’ compensation scheme — federal or state — applies, but they did not themselves purport to abrogate available general maritime remedies for those outside the LHWCA’s scope. Nor, under the supremacy clause of the federal Constitution, may the exclusive-remedy provision in California’s workers’ compensation scheme be applied to deprive a plaintiff of a substantive federal maritime right. Whether Ranger’s general maritime claims might be barred under other provisions of the LHWCA — and whether Ranger’s claims properly invoked admiralty jurisdiction in the first place — are issues the Court of Appeal has not yet addressed. We therefore reverse the judgment of the Court of Appeal and remand for further proceedings.”

Justice Evans authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Liu, Kruger, Groban, and Jenkins concurred.