The U.S. Court of Appeals for the Third Circuit affirmed a lower court judgment limiting when injured maritime workers can recover damages for future medical treatments, establishing important precedent for shipowner liability under maritime law.
In *Tammy Knieling v. Don Fung Fook and William Poston* (3d Cir. 2026), the appeals court upheld the principle that shipowners must cover injured sailors' medical expenses and living costs until reaching maximum medical improvement, but clarified limits on speculative future treatment claims.
The case arose when Tammy Knieling, working as first mate and chef aboard the 51-foot power catamaran M.B. Somewhere Hot, suffered a finger injury during rough seas. Captain Don Fung Fook had ordered Knieling to let out the dinghy line when her left hand became trapped between the taut line and a metal cleat. Despite her screams to stop the boat, the pressure was too great for her to free herself until the engines were cut.
A medical student aboard wrapped Knieling's injured left middle finger, and she continued working without missing any days. Shore-side medical examination revealed a broken and dislocated finger. Although the fracture eventually healed and her grip strength recovered, Knieling's left middle finger retained 20% less range of motion permanently.
Dr. Fletcher, a plastic and hand surgeon, provided treatment recommendations during Knieling's recovery process. The medical evidence showed that while Knieling had recovered from the acute injury, some functional limitations remained.
The Third Circuit opinion, written by Circuit Judge Bibas, emphasized the longstanding maritime law principle that "sailing is dangerous, so shipowners have long been responsible for their injured sailors' medical bills and living expenses." The court noted this duty continues until shipowners can demonstrate that injured sailors have reached maximum medical improvement.
Knieling successfully recovered all her past medical expenses and additional compensation through the lower court proceedings. However, she also sought damages for potential future medical treatments related to her finger injury. This aspect of her claim became the central issue on appeal.
The appeals court ruled that because the nature and necessity of any future treatments remained unclear, Knieling could not recover additional damages at this time. The court distinguished between established past medical expenses, which are compensable, and speculative future treatments that lack sufficient medical evidence.
"Because it is unclear what future treatments she may get to help her finger, she cannot recover more now, but may come back later," Judge Bibas wrote in the opinion. This language preserves Knieling's right to seek additional compensation should specific future treatments become medically necessary and clearly defined.
The decision reflects maritime law's balance between protecting injured seamen and preventing speculative damage awards. Under the Jones Act and general maritime law, shipowners bear significant responsibility for crew member injuries, including maintenance and cure obligations that cover living expenses and medical care during recovery.
The case originated in the U.S. District Court for the Virgin Islands under Magistrate Judge Ruth Miller, who initially ruled in favor of the defendants regarding future medical treatment coverage. The district court's judgment was appealed to the Third Circuit, which heard oral arguments on Dec. 9, 2025, before issuing its decision on Feb. 11, 2026.
The three-judge panel consisted of Circuit Judges Hardiman, Bibas, and Porter, with Judge Bibas authoring the unanimous opinion. The panel's composition brought extensive experience in maritime and civil litigation matters to bear on the complex questions of seaman injury compensation.
This ruling provides guidance for future maritime injury cases regarding the timing and evidence required for future medical treatment claims. While affirming robust protection for injured maritime workers, it establishes that damage awards must be based on reasonable medical certainty rather than speculation about potential future needs.
The decision also demonstrates the continuing vitality of traditional maritime law principles in modern commercial shipping contexts. Despite involving a relatively small charter vessel operation, the case reinforces that maritime employers cannot escape their fundamental obligations to injured crew members.
For maritime industry participants, the ruling clarifies that while the duty to provide maintenance and cure remains strong, future medical expense claims require specific medical evidence and cannot be awarded based on general possibilities of future treatment needs.
The case number 24-2613 adds to the Third Circuit's body of maritime law precedent, joining other recent decisions that have shaped the boundaries of shipowner liability and seaman compensation rights in the modern era.