Farrell v. United States
336 U.S. 511, 1949 U.S. LEXIS 2927, 93 L. Ed. 2d 850 (1949)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A shipowner's duty under maritime law to provide maintenance and cure to a seaman who falls ill or is injured in the service of the ship extends only until the point at which the seaman has reached maximum medical improvement, meaning the condition is cured or has been declared permanent and incurable.
Facts:
- Farrell, a 22-year-old seaman, served on the S.S. James E. Haviland, a merchant vessel owned by the United States.
- On February 5, 1944, while the ship was docked in Palermo, Sicily, Farrell was granted shore leave.
- Farrell overstayed his leave and, while returning to the ship in darkness and rain, he became lost.
- He was misdirected to the wrong area of the shore-front and fell over a guard chain into a drydock, suffering grievous injuries.
- As a result of the fall, Farrell was rendered totally and permanently blind and began to suffer from post-traumatic convulsions.
- Medical professionals determined that his condition was permanent, with no possibility of further cure, though he would require some future medical care to manage his symptoms.
Procedural Posture:
- Petitioner Farrell sued the United States in admiralty in a federal trial court, seeking damages under the Jones Act and maintenance, cure, and wages under maritime law.
- The trial court decided the issue of negligence against Farrell.
- The trial court awarded Farrell maintenance and cure up to the date he was discharged from the hospital as permanently disabled, and wages until the completion of the voyage.
- Farrell appealed to the intermediate appellate court, which affirmed the trial court's judgment.
- Farrell petitioned the United States Supreme Court for a writ of certiorari, which was granted.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a shipowner's duty to provide maintenance and cure to a seaman who suffers a permanent disability while in the service of the ship extend for the seaman's entire life?
Opinions:
Majority - Mr. Justice Jackson
No. A shipowner's duty to provide maintenance and cure does not create a lifelong pension; it is limited in time to the point where the maximum cure possible has been effected. The ancient maritime laws providing for lifetime maintenance were applicable only to seamen injured while defending the ship from attack, a situation not present here. The Court declined to create different levels of maintenance based on the cause of injury, as this would undermine the simplicity of the doctrine. The Court's holding is consistent with the Shipowners' Liability Convention, ratified by the United States, which provides that the obligation to pay ends when the incapacity is 'declared of a permanent character.' The Court also affirmed the lower courts' ruling that Farrell was only entitled to wages until the end of the voyage, not for the full twelve-month maximum term mentioned in his contract.
Dissenting - Mr. Justice Douglas
Yes, under these circumstances, the duty should extend beyond maximum cure. The majority's test is insufficient for cases where a seaman, after reaching maximum cure, is left permanently disabled and still in need of medical care to manage the condition. The policy behind maintenance and cure—to protect seamen and the nation's merchant marine—justifies making the enterprise bear the continuing costs of injuries sustained in its service. These future expenses are a legitimate cost of the business. The dissent also argued Farrell was entitled to wages for the full twelve-month term of his contract, not just the duration of the voyage.
Analysis:
This decision firmly establishes the 'maximum medical improvement' doctrine as the temporal limit for a shipowner's maintenance and cure obligation under general maritime law. It prevents the doctrine from evolving into a form of permanent disability pension or workers' compensation, thereby preserving its traditional character as a limited, no-fault remedy. The ruling reinforces the distinction between maintenance and cure (for recovery) and damages under the Jones Act (for negligence-based harm), ensuring that seamen do not receive lifetime benefits without a finding of fault. By rejecting a fact-intensive inquiry into the cause of injury for determining the duration of benefits, the Court maintained the doctrine's relative simplicity and predictability.
