Does a ship's owner have sufficient control to be considered an employer in a maritime employment relationship?

[31 Cal.3d 459] Such a limited degree of control might not be sufficient to establish a master-servant relationship in a land-based occupation. However, that is not true under maritime law. "Control is probably the most important factor" in determining whether an employment relationship exists in maritime as well as in common law cases. (United States v. Webb, Inc., supra, 397 U.S. at p. 192, 90 S.Ct. at p. 856.) However, in the maritime context, any determination must be informed by "necessities of the sea." (Id., at p. 191, 90 S.Ct. at p. 856.) One of these necessities is that seamen have greater discretion in the performance of their jobs than is usual in land-based occupations. (Id., at p. 192, 90 S.Ct. at p. 856.) As a result, unless "there is nearly total relinquishment of control through a bareboat, or demise, charter, the [ship]owner may ... be considered ... to have sufficient control to be charged ... an employer." (Ibid.)