## Facts

- Farrell, a 22-year-old merchant seaman in good health, served aboard the S.S. *James E. Haviland*, a merchant vessel owned and operated by the United States during wartime.
- On February 5, 1944, while the ship was docked at Palermo, Sicily, Farrell received shore leave requiring his return by 6 p.m.
- Farrell overstayed shore leave and, around 8 p.m., attempted to return in rain and darkness.
- He became lost, was misdirected to the wrong gate, and entered a blacked-out shore-front area about a mile from the ship.
- Farrell fell over a guard chain into a drydock that was lit for night work and suffered severe injuries.
- He received treatment in government hospitals until June 30, 1944, when he was discharged as completely disabled.
- Farrell became totally and permanently blind and suffered post-traumatic convulsions; he would require intermittent medical care for headaches and seizures, with no possibility of further cure.

## Issues

1. Whether a shipowner’s duty of maintenance and cure continues for life when a seaman is permanently disabled and incurable, or ends when maximum cure has been achieved.
2. Whether, under ship’s articles for a foreign voyage “from the United States and return” for a term “not exceeding” twelve months, a seaman is entitled to wages for twelve months from signing or only through completion of the voyage.

## Decision

- The Supreme Court affirmed the judgment for the United States.
- The Court held that liability for maintenance and cure does not extend beyond the time when maximum cure possible has been effected; Farrell was not entitled to maintenance for life or so long as he remained disabled.
- The Court held that, under the articles, Farrell was entitled to wages only until completion of the voyage, not for twelve months from the date of signing.
- Negligence was not before the Court because it had been decided against Farrell below and was abandoned.

## Legal Principles

- Maintenance and cure is owed when a seaman is injured or becomes ill in the service of the ship.
- The duty to provide maintenance and cure continues only until the seaman reaches maximum possible cure (maximum medical improvement), even if the seaman remains permanently disabled.
- Ongoing palliative or intermittent treatment after maximum cure does not, by itself, extend the shipowner’s maintenance-and-cure obligation indefinitely.
- Ship’s articles stating a foreign voyage “from the United States and return” for a term “not exceeding” a stated period generally create a voyage contract with an outside time limit, not a guaranteed fixed term of wages.
- Under such articles, wages are owed through completion of the voyage, not for the maximum period stated.

## Conclusion

The Court limited maintenance and cure to the period necessary to reach maximum possible medical recovery and interpreted “not exceeding twelve months” voyage articles to require wages only until the voyage ends, rejecting claims for lifetime maintenance and for wages through the maximum contractual cap.


Farrell v. United States, 336 U.S. 511 (1949)