In Re: In the Matter of the Complaint of Verplanck Fire District

── In Re: In the Matter of the Complaint of Verplanck Fire District ── Court: Court of Appeals for the Second Circuit Date: April 30, 2026 Category: General 23-1218 In Re: In the Matter of the Complaint of Verplanck Fire District UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT August Term, 2023 Argued: June 10, 2024 Decided: April 30, 2026 No. 23-1218 ______________________________________ IN RE: IN THE MATTER OF THE COMPLAINT OF VERPLANCK FIRE DISTRICT. VERPLANCK FIRE DISTRICT, as Owner of the Firefighting Vessel Marine I, for Exoneration from or Limitation of Liability, Petitioner-Appellee, v. TROY DYCKMAN, Claimant-Appellant. ∗ ______________________________________ Before: LEVAL, LOHIER, and LEE, Circuit Judges. Claimant-Appellant Troy Dyckman, a former volunteer firefighter with the Verplanck Fire District, appeals from the grant of summary judgment by the United States District Court for the Southern District of New York (Philip M. Halpern, J.) in favor of Petitioner-Appellee Verplanck Fire District. Dyckman suffered injury to his foot while traveling aboard a ship owned by the Verplanck Fire District to the reported site of a boat fire on the Hudson River, when he ∗ The Clerk of Court is respectfully directed to amend the official case caption as set forth above. 1 extended his leg to fend off a collision with another vessel. Having previously obtained compensation under New York’s Volunteer Firefighters’ Benefit Law, Dyckman filed this claim in response to the Fire District’s petition in the United States district court to limit its liability to the value of the vessel pursuant to the Limitation of Liability Act of 1851, 46 U.S.C. § 30523, and Rule F of the Supplemental Rules for Admiralty and Maritime Claims. His claim alleged (i) negligence and unseaworthiness pursuant to the Jones Act, 46 U.S.C. § 30104; (ii) unseaworthiness under Seas Shipping Co. v. Sieracki, 328 U.S. 85 (1946); and (iii) negligence under general maritime law. The district court granted summary judgment to the Fire District, finding that Dyckman was not eligible to bring claims pursuant to the Jones Act or Sieracki, and that the exclusive remedy provision of New York’s Volunteer Firefighters’ Benefit Law barred Dyckman from bringing his general maritime law claim. Dyckman appealed from the district court’s ruling, with the exception of the denial of his Jones Act claim. We conclude that the district court erred in ruling by summary judgment that Dyckman was not entitled to the warranty of seaworthiness extended to a Sieracki seaman, and in ruling that New York’s Volunteer Firefighters’ Benefit Law barred Dyckman’s federal negligence claim under general maritime law. Accordingly, we VACATE the judgment and REMAND to the district court. BRIAN J. SHOOT (Frank V. Floriani, Stephen C. Glasser, on the brief), Sullivan Papain Block McGrath Coffinas & Cannavo P.C., New York, NY, for Claimant-Appellant. GUERRIC S.D.L. RUSSELL, Nicoletti Hornig & Sweeney, New York, NY, for Petitioner- Appellee. LEVAL, Circuit Judge: Claimant-Appellant Troy Dyckman, formerly a volunteer firefighter with Petitioner-Appellee, the Verplanck Fire District (the “Fire District”), appeals from 2 a final judgment of the United States District Cou