## Facts

- James R. Coulter, a seaman employed by Ingram Pipeline, Inc. as a pipe-layer aboard barges, was injured on May 21, 1970.
- Ingram paid Coulter maintenance and cure at $10 per day and covered medical and hospital treatment until early February 1971.
- Coulter’s condition included severe, long-standing obesity; physicians believed further improvement required a strict, self-directed regimen of diet and exercise.
- The district court found Coulter “abandoned” the prescribed regimen and concluded he forfeited further maintenance and cure.
- Coulter maintained he had not reached maximum medical recovery, was not declared incurable, and did not willfully refuse treatment; he asserted he stopped the regimen after payments ended and he needed to work to support his family.

## Issues

1. Whether the district court clearly erred in finding that Coulter forfeited maintenance and cure by abandoning the prescribed diet-and-exercise program.
2. Whether, on this record, maintenance and cure could be terminated absent proof of maximum medical recovery or a willful and unreasonable refusal of beneficial medical treatment.

## Decision

- The Fifth Circuit reversed the judgment dismissing Coulter’s maintenance-and-cure claim and remanded for further proceedings.
- Applying Rule 52(a) clear-error review, the court concluded the forfeiture finding was not supported by the record.
- The court criticized the trial court’s forfeiture rationale as overly general and conclusory and insufficient to justify cutting off maintenance and cure.
- The court treated Coulter’s noncompliance with a demanding self-managed regimen—especially after payments ended and he needed income—as inadequate to show willful, unreasonable refusal of medical care.

## Legal Principles

- Appellate review of factual findings in admiralty follows Federal Rule of Civil Procedure 52(a); findings may be set aside only if clearly erroneous.
- Maintenance and cure is owed until the seaman reaches maximum medical recovery (maximum cure), meaning cure is achieved or the condition is determined permanent and incurable.
- A seaman forfeits maintenance and cure only upon a showing of willful and unreasonable refusal of medical treatment that would aid recovery; forfeiture is disfavored and must be supported by specific findings and record evidence.
- When assessing alleged noncooperation, courts must account for practical realities, including the character of the prescribed “treatment” and the seaman’s circumstances affecting compliance.

## Conclusion

The Fifth Circuit held that ending Coulter’s maintenance and cure based on his alleged abandonment of a self-directed diet-and-exercise program was clearly erroneous on this record, and it remanded because forfeiture requires a supported finding of willful, unreasonable refusal of beneficial treatment and maintenance and cure ordinarily continues until maximum medical recovery is established.


Coulter v. Ingram Pipeline, Inc., 511 F.2d 735 (5th Cir. 1975)