An interesting decision was issued from the Federal Middle District of Florida involving a yacht captain’s personal injury lawsuit. In this case, the captain filed a lawsuit in Florida state court asserting claims against his employers for Jones Act negligence, failure to provide him with a seaworthy vessel and failure to providing him with maintenance and cure benefits. As part of the complaint, the seaman also demanded that a jury decide all factual issues. Not wanting to have a state court judge and jury decide the case, the employers filed a declaratory judgment action in Federal court seeking a Federal judge, without a jury, decide whether the seaman waived his right to bring a Jones Act and maintenance and cure claim by signing an employment contract which contains a Marshall Islands law provision. The yacht captain moved to dismiss the Federal declaratory judgment action arguing that the court should not accept jurisdiction and allow the action to proceed in state court.
The Declaratory Judgement Act
The Declaratory Judgment Act gives Federal District Courts discretionary jurisdiction to accept a claim to declare the rights and obligations between parties in cases of which it would have original jurisdiction. Since a seaman’s contract is considered a maritime contract, a Federal court would have original jurisdiction to hear the case. A Court considers several factors in determining whether it should exercise its discretion when there is a pending parallel litigation. These factors include: (1) the strength of the state’s interest in having the issues raised in the federal declaratory action decided in the state courts; (2) whether the judgment in the federal declaratory action would settle the controversy; (3) whether the federal declaratory action would serve a useful purpose in clarifying the legal relations at issue; (4) whether the declaratory remedy is being used merely for the purpose of “procedural fencing”—that is, to provide an arena for a race for res judicata or to achieve a federal hearing in a case otherwise not removable; (5) whether the use of a declaratory action would increase the friction between our federal and state courts and improperly encroach on state jurisdiction; (6) whether there is an alternative remedy that is better or more effective; (7) whether the underlying factual issues are important to an informed resolution of the case; (8) whether the state trial court is in a better position to evaluate those factual issues than is the federal court; and (9) whether there is a close nexus between the underlying factual and legal issues and state law and/or public policy, or whether federal common or statutory law dictates a resolution of the declaratory judgment action. In addressing eight of the nine factors, the Federal Court determined that it should not accept jurisdiction.