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Media Alerts - James Joyce v. Maersk Line LTD - Third Circuit
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December 7, 2017
  James Joyce v. Maersk Line LTD - Third Circuit
Headline: Union contracts freely entered by seafarers will not be reviewed unless evidence of unfairness

Area of Law: Contract; Maritime Law

Issue(s) Presented: Does the holding in Barnes extend to unearned wages set by a collective bargaining agreement?

Brief Summary:

James Joyce, a member of the Seafarers International Union, filed a class action alleging that the unearned wages portion of his collective bargaining agreement with Maersk violated maritime law. Joyce's union agreement provided that if he were medically discharged before the conclusion of his contract, he would be entitled to unearned wages for the remainder of the contract. After being discharged due to kidney stones, Joyce claimed that he was entitled to overtime pay as part of his unearned wages. Joyce relied on the holding in Barnes, which established that a seafarer's maintenance could be modified by the court regardless of the collective bargaining agreement. The District Court granted summary judgment in favor of Maersk, finding that, under the bargaining agreement, Joyce was not entitled to overtime as a matter of law. On appeal, the Third Circuit overruled its decision in Barnes v. Andover Co. The Third Circuit recognized the importance of enforcing negotiated contracts. It, thus, held that a freely entered seafarer union contract will not be dissected and reviewed by courts unless there is evidence of unfairness within the collective bargaining process.


Extended Summary:

James Joyce is a member of the Seafarers International Union. He entered into a collective bargaining agreement with Maersk Line Limited for a three-month period. During this period, Joyce fell ill with kidney stones and was declared unfit for duty. Per his bargaining agreement, Joyce was entitled to unearned wages for the remainder of his contract. The agreement only provided for base pay, not for overtime. As a result, Joyce brought a class action suit, alleging that portions of the collective bargaining agreement violated general maritime law. The District Court granted summary judgment in favor of Maersk, finding that due to the agreement, Joyce was not entitled to overtime. Joyce filed an appeal, urging that the holding in Barnes v. Andover Co. should apply to his claim.

On appeal, the Third Circuit reconsidered its holding in Barnes. In Barnes, the Court held that a maintenance rate within a contract was not binding on a union member who could show higher daily expenses. In doing so, the Court parted ways from other circuits that held that contractual rates should be binding as long as there was a fair collective bargaining process. The Third Circuit disagreed, holding that contracts should not be permitted to override common law maritime rights provided to seamen.

Joyce argued that a seafarer's right to unearned wages should be treated exactly like the right to maintenance. In addition, he argued that overtime pay is part of the common law right to unearned wages. Relying on the Court's reasoning in Barnes, Joyce argued that an unearned wage rate in a collective bargaining agreement can be set aside if determined to be insufficient. The Court agreed with Joyce's first point, finding that there is a long history that demonstrates that seafarers are entitled to unearned wages. In addition, the Court noted that a common expectation of overtime could lead to the conclusion that overtime should be included in unearned wages. The Court further agreed that if it applied Barnes, Joyce would most likely succeed on his claim. However, given the conflicting opinions of other circuits with respect to collective bargaining, the Third Circuit reconsidered its holding in Barnes.

Barnes was based on the common law protections afforded to seafarers and the idea that the law should not allow union contracts to override those maritime rights. However, labor policies and federal labor law lends itself to the required adherence to the terms of a collective bargaining agreement. Judicial intervention is not as necessary as it was in the past. On review, the Third Circuit focused on the importance of enforcing privately negotiated contractual rates because seafarers do not need as much protection as they once did. The Third Circuit ultimately overruled Barnes, holding that a freely entered seafarer union contract will not be dissected and reviewed by courts unless there is evidence of unfairness within the collective bargaining process. In addition, the Court further limited the ruling by noting that maintenance, cure, and unearned wages could not be completely abrogated by contract. The Third Circuit affirmed the judgment of the District Court.

The full opinion can be found at http://www2.ca3.uscourts.gov/opinarch/163553p.pdf

Panel: Smith, Chief Judge; McKee, Ambro, Chagares, Jordan, Hardiman, Greenaway, Jr., Vanaskie, Shwartz, Krause, Restrepo, and Roth, Circuit Judges.

Argument Date: October 8, 2017

Date of Issued Opinion: December 4, 2017

Docket Number: No. 16-3553

Decided: Affirmed.

Case Alert Author: Kristina Flatley

Counsel: Dennis O'Bryan, Counsel for Appellant; John Walsh, Counsel for Appellee; Martin Davies, Amicus Curiae

Author of Opinion: Circuit Judge Jordan

Circuit: Third Circuit

Case Alert Circuit Supervisor: Professor Mary E. Levy

    Posted By: Susan DeJarnatt @ 12/07/2017 01:38 PM     3rd Circuit  

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