In Chandris, Inc. v. Latsis, 515 U.S. 347 (1995), the Supreme Court determined that a marine engineer who spent no more than 10% of his time on the vessels was a seaman under the Jones Act because he had a substantial connection to a fleet of vessels in navigation. In Chandris, the Court articulated a two-part test to determine seaman status under the Jones Act. First, the worker's "duties must contribute to the function of the vessel or the accomplishment of its mission." 515 U.S. at 368. Second, the worker "must have a connection to a vessel in navigation (or an identifiable group of vessels) that is substantial in terms of both its duration and its nature." Id. The Court noted that the Jones Act remedy was "reserved for sea-based maritime employees whose work regularly exposes them to the special hazards and disadvantages to which they who go down to sea in ships are subjected." Id. at 370. It explained that the substantial connection requirement was intended to "separate the sea-based maritime employees who are entitled to Jones Act protection from those land-based workers who have only a transitory or sporadic connection to a vessel in navigation, and therefore, whose employment does not regularly expose them to the perils of the sea." Id. at 368.