Skye v. Maersk Line, No. 12-164331 (11th Cir. 2014)
Annotate this CasePlaintiff, chief mate of the "Sealand Pride," filed suit under the Jones Act, 46 U.S.C. 30104, alleging that his employer, Maersk, negligently saddled him with excessive duties and duty time such that he was overworked to the point of fatigue. The court concluded that the Jones Act does not allow seaman to recover for injuries caused by work-related stress because work-related stress is not a physical peril. Therefore, the district court erred when it denied the motion of Maersk for a judgment in its favor as a matter of law. Under Consolidated Rail Corp. v. Gottshall, plaintiff's complaint of an injury induced by overwork was not cognizable under the Jones Act. Accordingly, the court vacated the judgment awarding plaintiff damages. The court reversed the denial of the motion of Maersk for a judgment as a matter of law and rendered the judgment in favor of Maersk.
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