William C. Skye v. Maersk Line
751 F.3d 1262
11th Cir.2014Background
- Skye served as chief mate aboard the Sealand Pride (operated by Maersk) from 2000–2008 with extensive overtime hours.
- He regularly worked 90–105 hours per week for long stints and faced arduous on-board tasks (cargo, inspections, ballast-tank work) that reduced rest.
- Cardiologist diagnosed benign arrhythmia in 2000; by 2008 he developed left ventricular hypertrophy linked to chronic job stress and long hours.
- Skye filed a Jones Act negligence claim in 2011 alleging inadequate rest, crew, and hours; his cardiologist tied the heart condition to job stress.
- Jury found a physical injury caused by work conditions with 75% comparative fault; damages awarded were later reduced; district court denied Maersk’s JMOL.
- The district court instructed the jury to classify injury as physical or emotional, applying Gottshall’s framework that work-related stress injuries are not cognizable under the Jones Act.
- The appellate court reversed, holding Skye’s injury not cognizable under the Jones Act as it concerns physical perils, not stress-related injuries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether work-related stress injuries are cognizable under the Jones Act | Skye argues the injury is physical and caused by work stress | Maersk argues Gottshall bars recovery for stress-based injuries | No; not cognizable under the Jones Act |
| Whether Gottshall’s zone-of-danger framework applies to Skye’s claim | Skye’s injury is physical; zone-of-danger should apply | Gottshall limits recovery to physical perils or zone of danger | Zone-of-danger not applicable to support recovery under Jones Act |
| Whether the district court erred in denying Maersk’s motion for judgment as a matter of law | Evidence supports physical injury linked to work stress | Under Gottshall, such injuries are not cognizable | District court erred; JMOL granted for Maersk |
Key Cases Cited
- Consolidated Rail Corp. v. Gottshall, 512 U.S. 532 (1994) (stress-related injuries not cognizable under FELA/Jones Act; focus on physical perils)
- O'Donnell v. Great Lakes Dredge & Dock Co., 318 U.S. 36 (1943) (statutory integration and scope of FELA; application to Jones Act)
- Norfolk & Western Ry. Co. v. Ayers, 538 U.S. 135 (2003) (limits on Gottshall; allows asbestosis-related pain within broader damages context)
- Szymanski v. Columbia Transp. Co., 154 F.3d 591 (6th Cir. 1998) (work schedule not a physical peril under FELA/Jones Act)
- Crown v. Union Pac. R.R. Co., 162 F.3d 984 (8th Cir. 1998) (recovery denied for conditions attributable to long hours)