Jody King v. Huntress, Inc.
94 A.3d 467
R.I.2014Background
- King, a deckhand on the fishing vessel Persistence, was injured on May 31, 2006 after a stepladder slipped while the vessel was docked; he later sued Huntress, Inc. for maintenance and cure, Jones Act negligence, and breach of the warranty of seaworthiness.
- Jury trial (Nov. 2010): jury awarded $257,500 on maintenance and cure (Count One) and found for Huntress on Jones Act and unseaworthiness (Counts Two and Three).
- After verdict, Huntress moved for a new trial on maintenance arguing an erroneous jury instruction about “unearned wages”; King moved for a new trial on Jones Act and unseaworthiness arguing the jury verdicts were against the weight of the evidence.
- Trial justice denied Huntress’s motion on maintenance (finding Huntress had not preserved/clearly stated its objection) and granted King’s motion on Jones Act and unseaworthiness (finding jury verdicts against preponderance). He also applied Rhode Island’s prejudgment interest statute (§ 9-21-10) rather than maritime law.
- Supreme Court reviewed: (1) jury instruction on unearned wages; (2) whether trial justice properly granted King a new trial on negligence/unseaworthiness; and (3) whether state prejudgment-interest law applied in admiralty action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1) Whether the trial court’s instruction that maintenance award should include “unearned wages” was correct | King: the instruction was a correct, straightforward statement and jury could infer an implied employment term | Huntress: instruction was legally incorrect — unearned wages require a voyage or a contract for a fixed employment term; no such contract existed | Held: Instruction was erroneous and incomplete; King was not entitled to unearned wages absent a voyage or fixed-term contract; remand for new trial on maintenance and cure |
| 2) Whether trial justice properly granted King a new trial on Jones Act negligence and breach of seaworthiness | King: reasonable minds could not have reached the jury’s defense verdicts; trial justice right to grant new trial | Huntress: trial justice overlooked or misconstrued material evidence, relied on deposition material not in evidence, and improperly disregarded favorable testimony | Held: Trial justice overlooked and misconceived material evidence (including inconsistent but exculpatory testimony he ignored); his grant of a new trial was clearly wrong — that grant is vacated |
| 3) Whether Rhode Island’s prejudgment-interest statute or federal maritime law governs prejudgment interest in admiralty claim tried in state court | King: the state statute applies; calculation is ministerial and preserves status quo; defendant waived by not requesting jury instruction | Huntress: prejudgment interest is substantive maritime issue; federal maritime law governs and the jury (not clerk) should decide prejudgment interest | Held: Prejudgment interest is a substantive admiralty matter; federal maritime law controls; trial justice erred in applying § 9-21-10 and in placing burden on defendant to request jury instruction |
| 4) Whether Huntress waived objection to unearned-wages instruction under Rule 51(b) | King: Huntress failed to state a distinct objection and thus waived it | Huntress: its on-the-record objection sufficiently identified the issue | Held: No waiver — Huntress’s objection, though inartful, alerted the court; waiver finding rejected as to the unearned-wages instruction |
Key Cases Cited
- Ferrara v. A. & V. Fishing, Inc., 99 F.3d 449 (1st Cir. 1996) (maintenance and cure is due largely without regard to fault; explains maintenance and cure scope)
- LeBlanc v. B.G.T. Corp., 992 F.2d 394 (1st Cir. 1993) (distinguishes maintenance and cure from compensatory lost wages)
- Robinson v. Pocahontas, Inc., 477 F.2d 1048 (1st Cir. 1973) (prejudgment interest in admiralty cases is governed by federal maritime law; jury discretion required unless properly requested)
- City of Milwaukee v. Cement Division, National Gypsum Co., 515 U.S. 189 (1995) (historical practice of awarding prejudgment interest in admiralty)
- Mitchell v. Trawler Racer, Inc., 362 U.S. 539 (1960) (owner’s absolute duty to provide seaworthy vessel; standard is reasonable fitness)
- Farrell v. United States, 336 U.S. 511 (1949) (absence of a fixed-term employment contract limits unearned-wages awards to end of voyage)
- Offshore Logistics, Inc. v. Tallentire, 477 U.S. 207 (1986) (savings-to-suitors clause permits state-court admiralty jurisdiction but federal maritime substantive law controls)