Confusion exists regarding the applicable duty of a vessel owner to longshore workers in LHWCA Section 905(B) cases.  Initially, the courts applied a strict liability unseaworthiness standard.  In 1972, Congress took away the longshore workers unseaworthiness claim when it enacted 33 U.S.C.A. § 905(b), and replaced it with a “negligence” action against the vessel.  In 1981, in Scindia Steam Navigation Co. v. De Los Santos, 451 U.S. 156 (1981), the Supreme Court narrowed the vessel’s duty for particular types of § 905(b) cases; namely, those by workers employed by a stevedoring company whose duties involved loading and unloading ships.  Instead of applying the Congressional “negligence” standard, the Court created 3, or possibly 6, sub-duties.  The lower courts soon began applying the Scindia construct beyond the factual situation in which it arose, often constraining and confusing what should be simple negligence cases.