James Joyce v. Maersk Line Ltd, 876 F.3d 502

Background

James Joyce, a unionized seafarer, signed Articles of Agreement with Maersk incorporating a collective bargaining agreement (CBA) for a three‑month voyage; he served as bosun on the MAERSK OHIO.
Joyce fell ill aboard, was medically discharged overseas, repatriated, and claimed entitlement to unearned wages for the remainder of his contract period.
The CBA defined unearned wages to exclude overtime; Joyce received only base pay for the unused contract period and sued claiming the CBA’s exclusion violated general maritime law.
The District Court granted summary judgment for Maersk, holding the CBA controlled and denied overtime as unearned wages.
On appeal the Third Circuit reconsidered its prior precedent in Barnes v. Andover, which had allowed courts to modify maintenance rates in CBAs, and reviewed whether that rule should extend to unearned wages.
The Third Circuit overruled Barnes, held that CBAs freely negotiated by union seafarers can define rates for maintenance and unearned wages, and affirmed the district court judgment.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a collective bargaining agreement can be judicially modified under general maritime law to add overtime to unearned wages	Joyce: maritime common law historically includes unearned wages (including overtime), so Barnes permits courts to set aside CBA rates that are insufficient	Maersk: CBA governs; courts should enforce freely negotiated CBAs and not redraft bargained terms	The CBA governs; courts will enforce bargained rates for maintenance and unearned wages unless the CBA or bargaining process is shown to be unfair or inadequate; Barnes overruled
Whether Barnes v. Andover remains binding precedent in the Third Circuit	Joyce: Barnes supports judicial review of bargained maintenance/unearned wage rates	Maersk: Barnes should not be applied; CBAs should be enforced consistent with labor policy	Barnes is overruled; Third Circuit adopts majority view of other circuits enforcing CBAs absent unfair bargaining
Whether common‑law maritime rights (maintenance, cure, unearned wages) can be entirely abrogated by contract	Joyce: common‑law rights protect seamen and should not be negated by contract	Maersk: CBAs may define and modify rates though not eliminate the underlying rights	The court: CBAs may modify rates and definitions but cannot wholly abrogate the fundamental common‑law remedies absent congressional action
What showing allows judicial intervention into a CBA rate for maritime remedies	Joyce: individual inadequacy of a bargained rate should permit judicial correction	Maersk: absent a challenge to the overall negotiation fairness, courts should defer	Held: judicial intervention permitted only when the seafarer alleges the CBA or the bargaining process as a whole was unfair or inadequate

Key Cases Cited

Barnes v. Andover Co., L.P., 900 F.2d 630 (3d Cir. 1990) (prior Third Circuit panel decision allowing judicial modification of bargained maintenance rates; overruled)
Gardiner v. Sea‑Land Serv., Inc., 786 F.2d 943 (9th Cir. 1986) (CBA maintenance rates binding if collective bargaining was fair)
Al‑Zawkari v. Am. Steamship Co., 871 F.2d 585 (6th Cir. 1989) (CBA rates enforceable against seamen who negotiated them)
Baldassaro v. United States, 64 F.3d 206 (5th Cir. 1995) (refusing to set aside CBA maintenance rate absent unfair bargaining)
Ammar v. United States, 342 F.3d 133 (2d Cir. 2003) (endorsing enforcement of CBA‑defined maintenance and related rates when bargaining was legitimate)
Frederick v. Kirby Tankships, Inc., 205 F.3d 1277 (11th Cir. 2000) (CBA remedies may alter maritime remedies; no relief where bargaining was fair)
Cabrera Espinal v. Royal Caribbean Cruises, Ltd., 253 F.3d 629 (11th Cir. 2001) (rates for maintenance, cure, and wages may be defined by collective bargaining)
Padilla v. Maersk Line, Ltd., 721 F.3d 77 (2d Cir. 2013) (overtime may be recoverable as unearned wages where overtime was a reasonable expectation)
Lipscomb v. Foss Mar. Co., 83 F.3d 1106 (9th Cir. 1996) (method for calculating maintenance, cure, and wages may be determined by collective bargaining)
De Zon v. Am. President Lines, Ltd., 318 U.S. 660 (1943) (fundamental duties like maintenance and cure cannot be completely abrogated by private agreement)