Fitzgeral v US Lines Co. case brief summary
Supreme Court, 1963
This case tells us that if you have a seafarer claim in the Jones Act and other acts, all those claims must be joined and all the claims must be submitted to the jury.
- Andres San Martin twisted and strained his back while working for US Lines.
- He brought action in the Southern District of New York, he claimed damages based on negligence and unseaworthiness of the ship, based on failure to provide him with medical attention, maintenance and cure and wages.
- The Jones act provides a jury trial for negligence, but the actions for unseaworthiness, maintenance and cure are traditional admiralty remedies which in the absence of a statute do not ordinarily require trial by jury.
- Andres demanded jury trial for all the actions.
- Although remedies for negligence, unseaworthiness, maintenance and cure have different origins and may call for application of different principles and procedures, they nevertheless, when based on a unitary set of circumstances, serve the same purpose of indemnifying a seaman for damages caused by injury, depend upon the same evidence and involve some identical elements of recovery.
- Requiring a seaman to split up his lawsuit complicated and confuses the trial.
- The judge must try to solve the puzzling problem of the bearing the jury’s verdict should have on recovery under the different standards of the maintenance and cure claim.
- While this court has held that the Seventh Amendment doesn’t require jury trials in admiralty cases, neither that amendment nor any other provision of the Constitution forbids them. Nor any statute of Congress or rule of procedure, civil or admiralty, forbid jury trials in maritime cases.
- Since the Jones Act requires jury in negligence actions, we would not be free to require submission of all the claims to the judge alone.
- A maintenance and cure claim joined with a Jones Act claim must be submitted to the jury when both arise out of one set of facts.
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