Aadland v. Boat Santa Rita II, Inc., No. 20-2073 (1st Cir. 2022)Annotate this Case
The First Circuit vacated in part and reversed in part the judgment of the district court in favor of Defendants in this action brought against the owners of a fishing vessel on which Plaintiff was a seaman alleging that the owners breached a federal common law obligation under admiralty law known as the "duty of cure," holding that the district court's holding rested on an impermissible ground for distinguishing Gauthier v. Crosby Marine Service, Inc., 752 F.2d 1085 (5th Cir. 1985).
Plaintiff alleged that Defendants failed adequately to pay him for the costs of the medical care he received after falling ill from an infection he acquired while working on their vessel and that, even if Defendants' various payments to Plaintiff and his private health insurer satisfied their duty of cure, their delay in paying him warranted an award of compensatory damages, punitive damages, and attorney's fees. The district court entered judgment for Defendants. The First Circuit largely vacated the judgment, holding (1) the district court's holding rested on an impermissible ground for distinguishing Gauthier and did not otherwise explain why Gauthier did not apply; and (2) Defendants' proposed alternative ground for affirming the district court's grant of judgment to Defendants on Plaintiff's breach-of-the-duty-of-cure claim failed.