crew, emergency, medical, treatment Home Publications Articles What is Prompt Enough? What is Prompt Enough? Articles Steamship Mutual Published: March 28, 2019 Contact author Download article pdf     Image On December 19 2018, the US Court of Appeal for the Fifth Circuit, in David J. Randle v Crosby Tugs, LLC. , affirmed the District Court summary judgment in favour of the vessel owner and highlighted the importance of dealing promptly with the manifestation of seafarers’ illness symptoms. The Fifth Circuit Court addressed two issues, ruling that: a) The Jones Act duty to provide a seafarer with prompt and reasonable care is not breached by calling emergency responders (911); and b) Shipowners cannot be held vicariously liable for the malpractice of non-agent medical providers. Background Randle, the plaintiff, suffered a stroke while working on board the ‘’Delta Force’’. The nature of his symptoms was not apparent but the Master, as soon as he was notified, called 911. Randle was transferred by emergency responders to the Teche Regional Medical Center Hospital (“TRMC”). TRMC doctors failed to correctly diagnose his medical condition and did not provide him with proper medication. As a result of the unsuitable medical treatment, Randle suffered a permanent disability. Randle commenced proceedings against Crosby Tugs (“Owners”) for negligence and unseaworthiness. His action was premised on an allegation for breach of the duty under the Jones Act, due to Owners’ negligence by failing to provide prompt and proper medical care. He further alleged that Owners were vicariously liable for the malpractice of the doctors at TRMC. Owners applied for a summary judgment to dismiss the claim. The US District Court agreed with Owners and dismissed both the negligence and unseaworthiness claims. Subsequently, Randle appealed against the Court’s decision which led to a review by the Court of Appeal for the Fifth Circuit of the duty of shipowners to provide prompt medical