Melvin Gualberto Medina Martinez v. Carnival Corporation
744 F.3d 1240
| 11th Cir. | 2014Background
- Martinez, seaman employed by Carnival on the Fascination, injured on the job and treated by Carnival-approved providers.
- Martinez signed a Seafarer’s Agreement containing an arbitration clause covering disputes arising under the agreement, including its existence, validity, or termination.
- Martinez filed state-law and federal claims in Florida; Carnival removed and moved to compel arbitration under CREFAA.
- District court granted arbitration, dismissed moot other motions, and administratively closed the case.
- Martinez appeals, challenging arbitration scope and survival of the agreement after termination; court must determine finality and arbitrability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the appeal is from a final decision under §16(a)(3). | Martinezargues finality because court terminated merits and left only arbitration. | Carnival contends order is interlocutory as it stayed or closed, not dismissed. | Yes; order is final and appealable. |
| Whether the Seafarer’s Agreement survives termination and arbitration applies. | Termination did not bar arbitration; clause survives. | Terminated contract cannot bind to arbitration in this claim. | Arbitration clause survives termination and governs the dispute. |
| Whether Martinez’s Jones Act claim falls within the arbitration scope. | Claim arising from seaman status and Carnival’s duties fits arbitration. | Dispute may not be covered if not arising under the agreement. | Dispute arising out of or in connection with the Seafarer’s Agreement is subject to arbitration. |
Key Cases Cited
- Rent-A-Center, W., Inc. v. Jackson, 561 U.S. 63 (2010) (presumption of arbitrability when ambiguity exists; gateway questions may be arbitrated)
- Green Tree Fin. Corp.-Ala. v. Randolph, 531 U.S. 79 (2000) (finality: ends litigation on merits; district court may dismiss claims and compel arbitration)
- Ray Haluch Gravel Co. v. Cent. Pension Fund of the Int’l Union of Operating Eng’rs & Participating Emp’rs, 134 S. Ct. 773 (2014) (functional finality; order that ends litigation on the merits is final)
- Doe v. Princess Cruise Lines, Ltd., 657 F.3d 1204 (11th Cir. 2011) (Jones Act claims dependent on seaman status; arbitrability under contract terms)
- Catlin v. United States, 324 U.S. 229 (1945) (finality standard; functional approach to final decisions)