In a recent decision, the Eleventh Circuit in Skye v. Maersk Line Limited, Corp., 751 F.3d 1262 (11th Cir. 2014), reversed a district court ruling awarding damages to a Jones Act seaman for injuries stemming from “excessive work hours and an erratic sleep schedule.” The Court’s decision in Skye reaffirms a now decades old prohibition on recovery under the Jones Act for injuries resulting from work-related stress.
From 2000-2008, the Plaintiff, William Skye, was employed as chief mate aboard a vessel operated by defendant, Maersk. During this time, Skye worked between 90 and 105 hours per week for periods of 70 to 84 days at a time. In 2003 Skye was diagnosed with a benign arrhythmia, and his cardiologist suggested that he get more rest. By 2008, Skye was experiencing headaches, back aches, and was diagnosed with a left ventricular hypertrophy, or thickening of the heart wall. In 2011, Skye brought a Jones Act negligence suit against his employer, Maersk, alleging that Maersk negligently failed to provide sufficient crew, reasonable working hours, and adequate rest hours. At trial, a jury awarded Skye $2,362,299.00, which the district court reduced to $590,574.75 as a result of Skye’s comparative fault. Maersk moved for a judgment as a matter of law, alleging that Skye’s injuries were not cognizable under the Jones Act based on Consolidated Rail Corp. v. Gottshall, 512 U.S. 532 (1994). The district court denied Maersk’s motion and rendered judgment in favor of Skye.
On appeal, the Eleventh Circuit noted that the Jones Act does not recognize all work-related injuries. The “central focus” of the Jones act is protection from “physical perils.” The Court found that Skye’s case failed for the same reasons as the case of the plaintiff in Gottshall. In Gottshall, the plaintiff’s complaint was similar to that of Skye’s. Both complained of injuries stemming from long hours and job-related stress. The Gottshall court, denied recovery to the plaintiff because work-related stress is “not caused by any physical impact.” Consistent with the precedent set by Gottshall, the Eleventh Circuit refused to expand the definition of “physical perils” to include an “arduous work schedule and an irregular sleep schedule.” The Court noted that it was not the development of a physical injury that brought a claim within the ambit of the Jones Act, but rather the cause of the injury. For an employer to become liable for an employee’s injury, it must be the result of a physical impact. Accordingly, the Court vacated the judgment of the district court and rendered judgment as a matter of law in favor of Maersk.
The Eleventh Circuit’s ruling in Skye reaffirms the common-sense understanding that work-related stress comes standard with all jobs. Similarly, individuals have varying levels of tolerance for stress. An employer should not become responsible for employee injuries resulting from an employee’s inability to manage work-related stress in an at-will employment relationship.