## Facts

- William T. Wright, an electrician serving as a seaman aboard a Maersk vessel, became seriously ill during a December 1997 voyage.
- The ship’s chief mate/medical officer monitored Wright, consulted a shoreside physician advisory service, and arranged to put Wright ashore for treatment at St. Helena.
- Wright alleged St. Helena’s isolation and limited facilities caused delayed and inadequate care, worsening his condition and prolonging his return to the United States.
- Wright sued Maersk for Jones Act/general maritime negligence and for unseaworthiness based on the decision to disembark him at St. Helena rather than another port with greater medical capacity and evacuation options.
- On summary judgment, the court allowed the negligence claim to proceed but dismissed the unseaworthiness claim.
- A jury later found Wright and Maersk each 50% at fault and found Wright’s total future lost earnings (before present-value reduction) to be $235,000.
- Post-verdict, the court had to select a net discount rate to reduce the future-earnings award to present value.

## Issues

1. What net discount rate should be used to reduce the $235,000 future lost-earnings award to present value: the defendant’s proposed 3% rate, the plaintiff’s proposed 2% rate, or another rate supported by the evidence?

## Decision

- The court held that a conservative net discount rate was appropriate for present-valuing future lost earnings.
- The court rejected Maersk’s proposed 3% net discount rate.
- The court adopted a lower net discount rate close to the 2% rate supported by Wright’s expert.
- The court applied the selected rate to convert the jury’s $235,000 future-earnings figure to present value and entered judgment consistent with the verdict and comparative-fault reduction.

## Legal Principles

- Future economic damages in Jones Act/general maritime cases must be reduced to present value.
- A “net discount rate” method may be used, reflecting a real (inflation-adjusted) rate derived from nominal interest and expected inflation.
- The discount rate must be evidence-based and realistic for a long-term award, commonly grounded in relatively safe, long-term government securities rather than optimistic investment assumptions.
- When expert testimony supports competing rates, the court may select a more conservative real rate to reduce the risk of under-compensating an injured seaman.

## Conclusion

The court’s post-verdict damages ruling selected a conservative, approximately 2% net discount rate to present-value the jury’s future lost-earnings award, rejecting a higher 3% rate as insufficiently conservative and entering judgment after applying present-value reduction and comparative fault.


Wright v. Maersk Line, Ltd., No. 99 Civ. 11282 (LMM), 2003 WL 470335 (S.D.N.Y. Feb. 26, 2003)