Eleventh Circuit Holds Jones Act Seaman Cannot Recover for Injuries Caused By Work-Related Stress
According to the Eleventh Circuit, the Jones Act does not allow a seaman to recover for injuries caused by work-related stress because it is not a “physical peril” under the Act. This ruling vacated a $590,574.57 judgment in which a jury found that a chief mate and manager of a commercial vessel was entitled to compensation for physical injuries that he sustained as a result of work-related stress.
The Eleventh Circuit based its decision on the U.S. Supreme Court decision in Consolidated Rail Corp. v. Gottshall, 512 U.S. 532 (1994), which interpreted the Federal Employers’ Liability Act (“FELA”). The Jones Act incorporates the remedial scheme of FELA and case law interpreting FELA also applies to the Jones Act, which finds that only injuries caused by “physical perils” present cognizable claims. The court found that per Gottshall, work-related stress does not constitute a physical peril under the Jones Act. Accordingly, the worker’s physical injury from the work-related stress was irrelevant, for the central question was whether the cause of the injury was actually a physical peril.
