James L. Joyce v. Maersk Line Ltd., 3d Cir. No. 16-3553, Dec. 4, 2017

The Third Circuit joins other Circuits on issue of modification of maritime labor contracts.

The United States Court of Appeals for the Third Circuit, in a precedential, en banc decision, ruled that judges may not modify the terms of a seafarer’s labor contract without evidence of unfairness in the collective bargaining process. This decision overruled its prior panel decision in Barnes v. Andover Co., L.P., 900 F.2d 630 (3d Cir. 1990), where the court had ruled that a maritime labor contract could not override common law protections for seafarers, enabling seafarers to establish a higher rate of maintenance than the agreed-upon contractual rate. The Third Circuit’s rationale in overruling Barnes was that seafarers are sufficiently protected through the union collective bargaining process, lessening the need for court intervention to further protect seafarers. The decision in Joyce aligned the Third Circuit with other federal appeals courts addressing this issue, including the First, Sixth and Ninth Circuits.


Case Law Alerts, 1st Quarter, January 2018

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