In Gold v. Helix Energy Solutions Group, Inc., No. 14-15-00123-CV, (Tex. App. Dec. 15, 2015) the Texas Court of Appeals has held that a drill ship that had been in dry dock for conversion for 20 months might still be regarded as being ‘in navigation’ and so within the Jones Act. The case arose out of an injury to a seaman on board the vessel while in drydock in Singapore. The Court of Appeals reversed the grant of summary judgment sought by the shipowners.