Hall v. Noble Drilling (U.S.) Inc.

This case involves the proper calculation of maintenance payments. The plaintiffs were injured during their employment on an offshore rig. The trial court awarded maintenance payments of $30.50/day and $31.50/day to the seamen respectively, noting that maintenance does not provide for expenses such as telephone or automobile bills, or the costs of supporting children.

The employer appealed, arguing that because the seamen lived with their families, their lodging expenses should have been divided among the members of the household and should only reflect the seamen’s pro rata share of food and lodging expenses. After a historical analysis of maintenance payments, the Court of Appeals noted that a seaman is entitled to the reasonable costs of subsistence while recuperating on land. This breaks down into two components: the reasonable cost of food and lodging for a seaman living alone, and the actual expenses for food and lodging that the seaman has incurred.

The employer argued that three or four people living together can live more cheaply than three or four people each living alone, and therefore maintenance should only cover a seaman’s pro rata share of lodging expenses when he lives with his family. The Court of Appeals disagreed, stating that reasonableness, not proration, is the proper limit on maintenance awards for seamen living with their families. The requirement that maintenance be limited to the reasonable expenses of a single seaman dispenses with the employer’s concern. Furthermore, the Court of Appeals noted that proration would punish a seaman for his thrift.

Therefore, a trial court must first estimate both the reasonable and actual expenses for food and lodging. The seaman’s burden is feather light in this regard. In determining reasonableness, the court can consider the seaman’s actual costs, evidence of reasonable costs in the locality or region, union contracts, and maintenance rates awarded in other cases for seamen in the same region. The trial court then compares the actual expenses to the reasonable expenses. The court awards the lower of the two, except if the court concludes that the seaman’s actual expenses were inadequate to provide him with reasonable food and lodging, the court must award the reasonable cost for food and lodging. Based upon the foregoing standards, the Court of Appeals held that the evidence supported the trial court’s awards of maintenance.