James Joyce v. Maersk Line Ltd

876 F.3d 502
CourtCourt of Appeals for the Third Circuit
DecidedDecember 4, 2017
Docket16-3553
StatusPublished
Cited by11 cases

This text of 876 F.3d 502 (James Joyce v. Maersk Line Ltd) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Joyce v. Maersk Line Ltd, 876 F.3d 502 (3d Cir. 2017).

Opinion

OPINION OF THE COURT

JORDAN, Circuit Judge.

Today we stop swimming against the tide of opinion on an important question of maritime law. Following the lead of several of .our sister circuits, we now hold that a union contract freely entered by a seafarer—a contract that includes rates of maintenance, cure, and unearned wages— will not be reviewed, piecemeal by courts unless there is evidence of unfairness in the collective bargaining process. In so holding, we overrule our decision in Barnes v. Andover Co., L.P., 900 F.2d 630 (3d Cir. 1990).

I. Background

The facts of this case áre not. in dispute. James Joyce was a member of the Seafarers International Union. He signed “Articles of Agreement” with the shipping company Maersk Line Limited and agreed to serve as a bosun aboard the MAERSK OHIO for a three-month period, from September 18, 2012 until December 18, 2012. The Union and Maersk had reached a collective bargaining agreement that governed the terms of all unionized seafarers’ employment with Maersk. The collective bargaining agreement was incorporated by reference into the Articles of Agreement between Joyce and Maersk.

Not long after the MAERSK OHIO departed as scheduled from the Port of Newark, New Jersey, Joyce fell ill. He was examined onboard and diagnosed with kidney stones. That diagnosis was later confirmed at a hospital in Spain, and he was declared unfit for duty and repatriated to the United States.

The collective bargaining agreement provided that, if a seafarer was medically discharged prior to the conclusion of his contract, he was entitled to unearned wages for the remaining period of the contract. Overtime was not included in the definition of unearned wages. Joyce accordingly received only base pay as unearned wages for the time left on his contract after he was medically discharged.

Dissatisfied, Joyce filed a putative class action in the United States District Court for the District of New Jersey. He alleged that the “portions of the [collective bargaining agreement] governing unearned wages ... violated general maritime law[.]” Joyce v. Maersk Line, Ltd., No. 13-5566, 2016 WL 3566726, at *1 (D.N.J. June 30, 2016). More particularly, he claimed that he was owed overtime pay. 1 Id. at *2. The District Court disagreed and granted summary judgment to Maersk on the ground that, as a matter of law, given the collective bargaining agreement, Joyce was not entitled to overtime. Id. at *6-7. In doing so, the Court distinguished our decision in Barnes. Id. We had said in that case that the specifics of what is covered by a seafarer’s right to “maintenance”— traditionally, the right to food and lodging expenses—could be modified by a court, even if those specifics were established in a collective bargaining agreement. Barnes, 900 F.2d at 640.

Joyce now asks us to overturn the District Court’s ruling on unearned wages. 2 Because seafarers were entitled at common law to both maintenance and unearned wages, he argues that our holding in Barnes should extend to unearned wages set by a collective bargaining agreement, making the union contract subject to change by court order to conform with traditional maritime law. His appeal presents an opportunity for us to reconsider our holding in Barnes. 3

II. Standard of Review

Because the District Court granted Maersk’s motion for summary judgment, we review its determination de novo, applying the same standard that it applied. Shelton v. Bledsoe, 775 F.3d 554, 559 (3d Cir. 2015). A “court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). There are no factual disputes at all in this case. Instead, we are faced with a pure question of law: whether, on the agreed facts, Maersk was entitled to judgment based on the collective bargaining agreement. Our review is thus plenary. See McCann v. Newman Irrevocable Tr., 458 F.3d 281, 286 (3d Cir. 2006) (explaining that we exercise plenary review over questions of law).

III. Discussion 4

A. Review of Barnes v. Andover Co., L.P., 900 F.2d 630 (3d Cir. 1990)

Joyce’s argument relies heavily on our holding in Barnes, so we turn to it first. The question in that case was whether a seafarer was bound by the maintenance rate set in a collective bargaining agreement between the shipowner and the seafarers’ union. Barnes, 900 F.2d at 631. We began our analysis by recognizing the deeply rooted duty at common law for a shipowner to pay a seafarer’s maintenance. Id. at 633. “Maintenance is the living allowance for a seaman while he is ashore recovering from injury or illness.” Id. It derives from medieval maritime laws and has long been recognized by American courts. Id. The right to “cure,” which is payment for “medical expenses incurred in treating the seaman’s injury or illnessf,]” has the same origin. Id.

The duty to pay maintenance and cure arose from what was viewed as the “peculiarity” of seafarers’ lives. Id. Justice Story explained the views of society at the time: “[seamen] are generally poor and friendless, and acquire habits of gross indulgence, carelessness, and improvidence.” Id. (quoting Harden v. Gordon, 11 F. Cas. 480, 483 (C.C.D. Me. 1823) (No. 6,047)). Thus, “[i]f some provision be not made for them in sickness at the expense of the ship, they must often in foreign ports suffer the accumulated evils of disease, and poverty, and sometimes perish from the want of suitable nourishment.” Id. (quoting Harden, 11 F. Cas. at 483). By imposing the duty on shipowners to pay for maintenance and cure, “the interest of the owner will be immediately connected with that of the seamen.” Id. (quoting Harden, 11 F. Cas. at 483). That arrangement benefitted both seafarers and owners—the former had the benefit of someone “watch[ing] over their health with vigilance and fidelity,” and the latter had employees who were “urge[d] ... to encounter hazards in the ship’s service.” Id. (quoting Harden, 11 F. Cas. at 483).

Those duties remain in maritime law. Indeed, in Barnes we observed that, besides being long entrenched in maritime law, the responsibility to pay maintenance and cure has been “construed liberally” and “consistently expanded” by the courts. Id. The scope of that responsibility extends “beyond injuries sustained on board ship or during working hours” and is in force “until the seaman has reached the point of maximum cure.” Id. at 633-34. The right to maintenance and cure exists “regardless of ... fault” by the seafarer. Id. at 633. Only in eases of willful misconduct has a seafarer been held to be outside the scope of the right. Id.

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Bluebook (online)
876 F.3d 502, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-joyce-v-maersk-line-ltd-ca3-2017.