Anderson v. MSC Cruises, S.A.

CourtDistrict Court, S.D. Florida
DecidedMarch 31, 2025
Docket0:24-cv-60715
StatusUnknown

This text of Anderson v. MSC Cruises, S.A. (Anderson v. MSC Cruises, S.A.) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. MSC Cruises, S.A., (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-60715-CIV-SINGHAL

MARLON LEONEL MITCHELL ANDERSON,

Plaintiff,

v.

MSC CRUISES, S.A.,

Defendant. ______________________________________/ ORDER ADOPTING MAGISTRATE JUDGE’S REPORT

THIS CAUSE is before the Court on Defendant MSC Cruises, S.A.’s (“MSC” or “Defendant”) Motion to Compel Arbitration (the “Motion”) (DE [9]), filed on May 6, 2024. Plaintiff Marlon Leonel Mitchell Anderson (“Anderson” or “Plaintiff”) filed his Opposition to Defendant’s Motion to Compel Arbitration (the “Opposition”) (DE [17]) on June 4, 2024. Defendant filed its Reply in Support of the Motion to Compel Arbitration (the “Reply”) (DE [21]) on June 25, 2024. Plaintiff also filed an additional Reply in Support of His Request to Remand (“Plaintiff’s Reply”) (DE [22])1 on July 2, 2024. As such, the Motion was ripe for adjudication by the Court. The Motion was referred to Magistrate Judge Jared M. Strauss for a Report and Recommendation (“R&R”) on December 30, 2024, pursuant to 28 U.S.C. § 636(b)(1), Fed. R. Civ. P. Rule 72, and the Magistrate Rules of the Local Rules of the Southern District of Florida. See (DE [27]). The magistrate judge issued an R&R on February 5, 2025, recommending that the Motion be granted. See (DE [30]). Judge Strauss found

1 Plaintiff’s Reply came without leave of the Court. See S.D. Fla. L. R. 7.1(c)(1). that the Court should apply federal common law to threshold questions of arbitrability, including the application of equitable estoppel to MSC’s attempt to compel arbitration. Judge Strauss also concluded that equitable estoppel doctrine dictates that MSC can compel arbitration even as a non-signatory to the Espit employment contract. Mr.

Anderson filed his Objections to Report and Recommendation and Request for De Novo Review (the “Objections”) (DE [31]) on February 19, 2025. MSC filed its Response in Opposition to Plaintiff’s Objections to Report and Recommendation (the “Response to Objections”) (DE [34]) on March 14, 2025. Mr. Anderson filed his Reply in Support of His Objections to Report and Recommendation and Request for De Novo Review (the “Reply in Support”) (DE [35]) on March 21, 2025. The Court has reviewed all appropriate filings and the record and is fully advised in the premises. In addition, the Court has conducted a de novo review of the R&R given Mr. Anderson’s objections. See Williams v. McNeil, 557 F.3d 1287, 1291 (11th Cir. 2009) (citing 28 U.S.C. § 636(b)(1)).

I. BACKGROUND The Court will not rework the facts, background, and applicable legal standards that were articulated by Judge Strauss. This Court adopts Judge Strauss’s description of the factual and procedural background and the applicable legal standards in the Report and Recommendation (DE [30]) and incorporates that background by reference herein. Mr. Anderson worked on one of MSC’s cruise ships, M/V MSC SEASIDE (“Seaside”), even though he had been hired by Espit Ventures PTE, LTD. (“Espit”). (DE [5] at ¶¶ 11-13). On May 22, 2023, while purportedly “on duty and in the service of the vessel,” Mr. Anderson fell while descending a flight of stairs. Id. at ¶ 23. Mr. Anderson subsequently filed a Seaman’s Complaint and Demand for Jury Trial (DE [1-2]) in the Circuit Court of the 17th Judicial Circuit In and For Broward County, Florida on April 2, 2024. That same day, Mr. Anderson commenced arbitration proceedings against Espit in Panama with the International Centre for Dispute Resolution, consistent with the arbitration clause in Mr. Anderson’s employment contract with Espit. See (DE [9-1]).

On April 29, 2024, MSC filed a Notice of Removal of Civil Action, Pursuant to Rule 9 U.S.C. § 205 and 28 U.S.C. § 1441 (DE [1]), removing the case to this Court. Soon after, on April 30, 2024, Mr. Anderson filed an Amended Complaint (DE [5]). Mr. Anderson’s Amended Complaint featured four counts against MSC: Jones Act Negligence, Unseaworthiness, Tortious Failure to Provide Maintenance and Cure, and Failure to Provide Prompt, Proper, and Adequate Medical Care. (DE [5]). Now, with this instant Motion, MSC seeks to compel Mr. Anderson to arbitrate his claims against MSC in the ongoing arbitration proceedings with Espit in Panama. In MSC’s view, Maltese law should be considered “the relevant law for the Panamanian arbitration,” which would allow MSC to compel arbitration based on the provision in Mr.

Anderson’s contract with Espit. (DE [9] at p. 3). MSC, however, also puts forward an alternative basis for standing to invoke arbitration, namely that Mr. Anderson’s claims against MSC are rooted in the same facts and are “intertwined.” Id. at p. 5. As stated previously, Judge Strauss did not concur that Maltese law governed the “interpretation of the [Espit] contract as a whole, including threshold inquiries of arbitrability.” (DE [30] at p. 7). To be sure, Judge Strauss did not find Singaporean or Nicaraguan law to be applicable either. Id. Rather, Judge Strauss reasoned that federal common law was suitable for “threshold questions of arbitrability, including the application of equitable estoppel to MSC’s attempt to compel arbitration. . .” Id. at p. 11. Judge Strauss further concluded that MSC can compel arbitration, even as a non-signatory, because Mr. Anderson alleged “substantially interdependent and concerted misconduct” by Espit and MSC that was “intimately connected” with the Espit contract. Id. at p. 16. In his Objections, Mr. Anderson puts forward a handful of challenges to the R&R.

He suggests, for instance, that the R&R discharged MSC’s burden of proof, which was both “legal error and violation of Plaintiff’s due process.” (DE [31] at p. 7). In addition, Mr. Anderson argues the R&R’s application of equitable estoppel was flawed and broke with precedent. Id. at p. 10. II. STANDARDS OF REVIEW A. Review of a Magistrate Judge’s Report and Recommendation When a party objects to a magistrate judge's findings, the district court must “make a de novo determination of those portions of the report ... to which objection is made.” 28 U.S.C. § 636(b)(1). The district court “may accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” Id. The district court

must consider the record and factual issues independent of the magistrate judge's report, as de novo review is essential to the constitutionality of § 636. Jeffrey S. v. State Bd. of Educ., 896 F.2d 507, 513 (11th Cir. 1990). B. Motion to Compel Arbitration For cases that center on an arbitration agreement involving foreign parties, the Court must consider the U.N. Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the “New York Convention”), June 10, 1958, 21 U.S.T. 2517, 330 U.N.T.S. 3, and its implementing legislation, Chapter 2 of the Federal Arbitration Act (“FAA”), 9 U.S.C. §§ 201–208. Escobar v. Celebration Cruise Operator, Inc., 805 F.3d 1279, 1283–84 (11th Cir. 2015) (citations omitted).

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Anderson v. MSC Cruises, S.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-msc-cruises-sa-flsd-2025.