## Facts

- A seaman employed by the shipowner alleged he injured his back while working aboard the vessel.
- He filed one civil action asserting three claims arising from the same accident: Jones Act negligence, unseaworthiness, and maintenance and cure (including related wages).
- He demanded a jury trial on all issues.
- The district court submitted negligence and unseaworthiness to the jury but reserved maintenance and cure for a later, nonjury trial before the judge.
- The jury found for the shipowner on negligence and unseaworthiness.
- After additional testimony, the judge awarded a small amount for maintenance and cure.
- The court of appeals affirmed, with judges divided on whether a jury trial on maintenance and cure was improper, discretionary, or required when joined with a Jones Act claim.

## Issues

1. Whether a maintenance and cure claim, when joined with a Jones Act negligence claim arising from the same incident and accompanied by a jury demand, must be submitted to the jury rather than tried separately to the court.

## Decision

- The Supreme Court reversed.
- It held that when a maintenance and cure claim is joined with a Jones Act claim and both arise out of the same set of facts, the maintenance and cure claim must be submitted to the jury.
- The case was remanded for proceedings consistent with requiring jury determination of maintenance and cure in the unified trial setting.

## Legal Principles

- A seaman has a statutory right to a jury trial on a Jones Act negligence claim.
- Although maintenance and cure is a traditional admiralty remedy not ordinarily requiring a jury, that claim must be tried to the jury when joined in the same action with a Jones Act claim arising from the same incident.
- Claims arising from a single accident should be tried by a single factfinder to avoid fragmented litigation, duplicative proof, and inconsistent factual determinations.
- The right to a jury determination of maintenance and cure in this joinder context is not defeated merely because the jury has already returned an adverse verdict on the Jones Act claim.

## Conclusion

The Court required unified jury adjudication of factually related Jones Act and maintenance and cure claims, directing that maintenance and cure be submitted to the same jury when the claims arise from one incident and are brought together in a single action.


Fitzgerald v. U.S. Lines Co., 374 U.S. 16 (1963)