A Florida Federal court has recently found that an injured maritime worker has a right to a jury trial for his Jones Act negligence, unseaworthiness and failure to provide maintenance and cure claims asserted as counter-claims to his employer’s admiralty declaratory judgment action.
Facts of the Case
In this case, a maritime worker sustained a back injury while standing watch aboard a ship. From this incident, he demanded that the ship owners provide him maintenance and cure benefits which is benefit owed to seamen who are injured while in call of the vessel regardless of fault. Two days after receiving the maintenance and cure demand, the ship owners filed a declaratory judgment action under the Declaratory Judgment Act seeking a Florida Federal court to determine that maintenance and cure is not owed because the maritime worker failed to qualify as a seaman. In bringing the declaratory judgment action, the ship owners invoked the court’s admiralty jurisdiction which does not carry the right of a jury trial. The injured maritime worker answered the declaratory judgment action and filed a counter-claim against the ship owners seeking damages under the legal theories of Jones Act negligence, unseaworthiness and failure to provide maintenance and cure. Along with the counter-claim, the injured maritime worker demanded a jury trial. The ship owners moved to strike the jury trial demand on the basis that jury trials are not available in admiralty proceedings.
The issue before the Florida Federal court is whether the injured maritime worker has the right to a jury trial when the lawsuit was initiated by the ship owners under the court’s admiralty jurisdiction. The injured maritime worker argued that he has a right to a jury trial under both the Seventh Amendment and the statutory language of the Jones Act. He also argued that the invocation of the Declaratory Judgment Act in an apparent attempt to prevent his exercise of his constitutional and statutory rights to a jury trial contravenes the Supreme Court’s repeated instruction that the Declaratory Judgment Act “leave[s] substantive rights unchanged.” The court agreed with the injured maritime worker and denied the motion to strike the jury trial demand. In its well-reasoned opinion, the court found that ship owners cannot preclude injured maritime workers’ jury right by simply beating him to the courthouse. Since the injured maritime worker has the right to a jury trial, the Declaratory Judgment Act cannot be used to preclude such a right, and the declaratory judgment action does not seek a ruling on whether the shipowners were negligence, the ship’s unseaworthiness or whether they failed to provide maintenance and cure. Therefore, the injured maritime worker has the right to a jury despite the court’s admiralty jurisdiction was invoked.
Import of the Decision
The ruling in this case is important to injured maritime workers. Ship owners and employers often times attempt to prevent a jury to resolve an injured person’s lawsuit by preemptively filing in Federal court and invoking admiralty jurisdiction. Cases such as this one can be argued in the future against such practices and to preserve the right to a jury trial.