An appeals court has delivered another blow to a widow's efforts to hold NYK Reefers and Cool Carriers responsible for the death of a dockworker after a steel lifting tray was dropped on him while inside a ship's hold.

The three-judge panel of the US Eleventh Circuit Court of Appeals ruled that Nippon Yusen Kaisha (NYK Line)'s reefer-owning arm and the Swedish operator were entitled to rely on stevedores to carry out the job properly in the operation that led to the death of longshoreman Robert Dixon.