Bartholomew and Ors v Crowley Marine Services Inc (The "Sea Voyager") - US Court of Appeals (9th Circuit)(Donald P Lay, Alfred T Goodwin and Ronald M Gould Ct JJ) - 30 July 2003

Salvage - Tug owned by salvage company rendering salvage services to another tug owned by same company - Whether crew members of salving tug entitled to salvage award - Whether tug-owning company also entitled to share of salvage award

The plaintiffs were crew members of the tug Sea Voyager, owned by the defendant salvage company, when it provided salvage services to another of the defendant's tugs, the Sea Vixen and its barge loaded with cargo. The plaintiffs sued the defendant for salvage. The defendant contended that the plaintiffs had done no more than perform their duties as employees of the defendant, which was engaged in salvage business.