Appeals court revives injured Verplanck firefighter’s maritime claims

A federal appeals court on April 30, 2026 revived two maritime claims by former Verplanck volunteer firefighter Troy Dyckman, vacating a judgment in the fire district’s favor and sending the case back for further proceedings. The ruling did not determine liability or award damages. [p. 1] [p. 6] [p. 65] [p. 68] [Official opinion]

The opinion describes the Verplanck Fire District as providing basic life support and fire protection to the hamlet of Verplanck. Its fireboat, Marine I, serves the northern Westchester stretch of the Hudson River. According to the court’s account, Dyckman was injured aboard the boat during an August 9, 2020 response to a reported boat fire. [p. 3] [p. 4] [Official opinion]

Dyckman had received benefits under New York’s Volunteer Firefighters’ Benefit Law. The district sought to limit its liability under federal vessel-owner law. After the lower court ruled for the district, Dyckman appealed the dismissal of his unseaworthiness claim under the Sieracki doctrine and his negligence claim under general maritime law. He did not appeal the denial of his Jones Act claim. [p. 3] [p. 5] [p. 6] [Official opinion]

The unseaworthiness claim concerns a vessel owner’s duty to provide a boat and equipment reasonably fit for their intended use. The appeals court rejected the lower court’s reasons for excluding Dyckman: that he was employed by the vessel owner, worked mainly on land and did not primarily aid navigation. Those characteristics did not automatically disqualify him from the Sieracki remedy. [p. 8] [p. 16] [p. 20] [p. 21] [Official opinion]

The court held that 1972 amendments to the federal Longshore and Harbor Workers’ Compensation Act did not abolish that remedy for workers excluded from the act’s coverage, including governmental employees. Dyckman was outside that federal compensation system. But the panel left the lower court to decide whether his actual work and exposure to maritime hazards qualified him for the remedy; that question had not been adjudicated on summary judgment. [p. 41] [p. 42] [Official opinion]

On negligence, the district relied on the state law’s provision making benefits the exclusive remedy against the employer. Dyckman argued that federal maritime law could not be displaced by that state restriction. The panel weighed state and federal interests rather than adopting a rule that federal maritime law always overrides state law. On these facts, it rejected the state provision as a bar to whatever maritime remedies Dyckman could prove. [p. 43] [p. 61] [p. 63] [p. 67] [Official opinion]

The April 30 decision left factual questions for the district court, including whether the evidence should be believed and whether Dyckman was performing seaman’s work and facing seaman’s hazards. It did not establish that the district was negligent, that the boat was unseaworthy or that Dyckman was owed a particular payment. [p. 1] [p. 65] [p. 68] [Official opinion]

This report covers the historical appellate ruling. The underlying pleadings, complete case record and later orders have not been independently obtained; the case’s present outcome and any next court date remain unverified. [p. 1] [p. 68] [Official opinion]