CA1: laches on the high seas

Doyle v. Huntress, Inc., Nos. 07-1396, 07-1506.  Some fishermen went to sea and were paid based on oral agreements under the "lay share system," (which gives them a percentage of the profits.)  So, we go to admiralty.  Under 46 U.S.C. § 11107, seamen can sue their employers for wages as 46 U.S.C. § 10601 requires that the seamen be given pre-trip written agreements.  But, the District Court said that there were laches and waives issues that needed to be resolved at trial.  The plaintiffs took an interlocutory appeal, and the District Court was affirmed in Doyle v. Huntress, Inc. (Doyle II), 419 F.3d 3, 15 (1st Cir. 2005) (our coverage here).  At trial, the seamen received very low amounts.

Insert fisherman joke and keep reading. 

 

To determine the substance of laches in admiralty, the caselaw directs the First to look at an analogous statute of limitations period.  The First sides with the District Court that the correct analogue is state law for wage claims (not the FLSA or the general ten-year statute of limitations).  The First reasons that the FLSA doesn’t apply since it excludes fishermen, and most federal courts look to state law to resolve laches issues and “Finally, given admiralty law's traditional hospitality towards seamen, it would be dissonant to give seamen less protection for the timeliness of their wage claims compared to the wage claims of their non-nautical neighbors in Rhode Island.”

The First says that the Rhode Island wage statue R.I. Gen. Laws § 28-14-20 is more analogous, and the doctrine of “hospitality towards fishermen” doesn’t mean that courts must go with the longer one.  The court notes that any argument regarding whether such wage claims would be brought by the state really goes to whether the delay in bringing a claim was reasonable or not. 

With that done, the First affirms the above awards, stopping to note that the defendants wanted to make the small awards smaller, and its proposed method of calculation should have been based on a recalculation of profits, but the First says that isn’t what the statute doesn’t provide for lost profits (only wages).