Joyce v. Maersk Line Ltd, No. 16-3553 (3d Cir. 2017)Annotate this Case
Joyce, a member of the Seafarers Union, agreed to serve as a bosun aboard the MAERSK OHIO for three months in 2012. The Union and Maersk had a collective bargaining agreement (CBA) that was incorporated by reference into the Agreement. Joyce fell ill onboard, was declared unfit for duty, and repatriated to the U.S. The CBA provided that, if a seafarer was medically discharged before the conclusion of his contract, he was entitled to unearned wages for the remaining contract period. Overtime was not included in the definition of unearned wages. Joyce received only base pay for the time left on his contract after his discharge. Joyce alleged that the CBA provisions governing unearned wages violated general maritime law. The district court granted Maersk summary judgment, distinguishing the Third Circuit’s 1990 “Barnes” holding that the specifics of what is covered by a seafarer’s right to “maintenance” (traditionally, food and lodging expenses) could be modified by a court, even if those specifics were established in a CBA. The Third Circuit affirmed, overruling the Barnes decision and joining other circuits, holding that a union contract freely entered by a seafarer that includes rates of maintenance, cure, and unearned wages will not be reviewed piecemeal by courts unless there is evidence of unfairness in the collective bargaining process.