This case provides a good reminder why an injured maritime worker should never sign any document without first consulting with a maritime lawyer.
The plaintiff, Jeremiah Hill, a Jones Act seaman employed by the defendant Jackson Offshore Holdings, LLC, sustained serious injuries while working aboard a vessel owned by the Jackson Offshore. While Hill was recovering, Jackson Offshore convinced Hill to sign an agreement to submit any future claims to binding arbitration before the Society of Maritime Arbitrators in exchange for continuing financial assistance. The agreement included a delegation clause to arbitrate disputes over the validity of the agreement itself.
Hill argued that Jackson Offshore’ s CEO, Lee Jackson, coerced him into signing the agreement by threatening to cut off financial assistance if Hill retained a lawyer. Hill claims he was not given a chance to review the agreement or consult a lawyer, and Jackson did not explain the terms or Hill's rights as a seaman. Hill felt he had no choice but to sign due to his complete financial dependence on the defendant. He would not have signed had he understood his rights.
Jackson Offshore argued that the delegation clause requires the arbitrator, not the court, to decide challenges to the validity of the arbitration agreement, per the Supreme Court's decision in Rent-A-Center v. Jackson. Jackson Offshore contended Hill is challenging the agreement as a whole, not the delegation clause specifically, so the court must compel arbitration.
The Court found that Hill's challenge to the agreement based on fraud and duress applied equally to the delegation clause. Under Rent-A-Center and the Supreme Court's recent decision in Coinbase v. Suski, the Court found it must address such challenges before compelling arbitration. The Court allowed Hill to conduct limited discovery on the enforceability of the arbitration agreement before revisiting the defendant's motion to compel arbitration.
A copy of the decision is provided below:
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Thanks,
Adam Davis
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