The Ryan doctrine arose out of the Byzantine complexities of pre-1972 longshoreman’s personal injury litigation. To make a long story1 short, because the liability of shipowners to shoreside workers under the vessel’s expanded seaworthiness coverage established by Seas Shipping Co. v. Sieracki 2 was quite burdensome and often unfair, the Supreme Court in Ryan Stevedoring Co. v. Pan-Atlantic Steamship Corp.3 held that (1) a warranty of workmanlike service or performance [WWLP] was implied in the vessel/stevedore contract, and that (2) based upon the WWLP, the ship sued by a longshoreman for breach of the seaworthiness warranty was entitled, in appropriate cases, to obtain full indemnity from the stevedoring company for breach of the implied WWLP.

Congress in 1972 amended4 the Longshoremens and Harbor Workers Compensation Act5 [LSHWCA]:

“among other things, to eliminate the shipowner’s liability to the longshoreman for unseaworthiness and the stevedore’s liability to the shipowner for unworkmanlike service resulting in injury to the longshoreman—in other words, to overrule Sieracki and Ryan” 6

While that statement has the usual benefits of short statements labelled “in other words,” it is not completely accurate. “In other words,” Ryan is not exactly overruled.

In fact, the Ryan doctrine consists of two entirely separate holdings, both of which still live, in part at least. It is crucial for purposes of post-1972 legal development