Grooms v. Marquette Transportation Company, LLC, involved an arbitration clause in a seaman's employment contract. Plaintiff was hired by Defendants as a deckhand. As part of his employment application, Plaintiff was required to be bound by a Dispute Resolution Program which included an arbitration provision. This provision included arbitration of claims for maintenance and cure as well as claims arising under the Jones Act.
Plaintiff was thereafter injured while working on a vessel afloat on the Mississippi River and filed suit under the Jones Act and general maritime law. The Defendants filed a counterclaim seeking a declaration that Plaintiff was bound by the arbitration agreement.
Because the contract was an employment contract of a seaman, the Federal Arbitration Act did not apply. The Plaintiff argued that § 5 of FELA, which provides that any contract that will enable a common carrier to exempt itself from civil liability is void, is incorporated into the Jones Act voiding the arbitration agreement because it will cause the Plaintiff to forego substantive statutory rights. In response, the court noted that the Plaintiff did not forego any substantive rights by agreeing to arbitrate his claims. Instead, the Plaintiff was simply submitting to the resolution of his claims through arbitration. The court also noted that other courts have similarly concluded that § 5 does not prohibit seaman arbitration agreements under state law. Therefore, the court held that the arbitration clause was enforceable under state law, the Illinois Uniform Arbitration Act.
This decision was handed down by a federal district court in the Southern District of Illinois. It is not known if this decision has gone up on appeal. Nonetheless, it will be interesting to see if this portends a new trend in maritime employment contracts and, if so, the ultimate consequences.
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