Griffin v. Oceanic Contractors, Inc. 458 U.S. 564, 102 S Ct. 3245, 73 L.ED.2d 973 (1982)
Griffin got a job working on
Oceanic's boat in the North Sea. He was injured on the job a few weeks
When he got out of the
hospital a few days later, Oceanic terminated his contract, sent him home,
and docked him the cost of the plane ticket.
Griffin sued in Admiralty
Court for lost wages and unpaid medical expenses.
Specifically under the Jones
Act (46 U.S.C. §596), which allowed seamen to recover double
their wages when payment is delayed without sufficient cause.
The amount of 'lost wages'
that Griffin was seeking was the $412 that Oceanic docked him for the
cost of the plane ticket.
The Trial Court found for
Griffin and awarded $23k, including almost $7k in lost wages. Oceanic
The Trial Court assessed the
double wage penalties for every day between Griffin's termination and the
day he found a new job (34 days)
Griffin argued that the
penalty should be assessed for every day between when he earned the money
and when Oceanic finally lost the court case and paid him (over 4
The Appellate Court affirmed.
The Appellate Court agreed
that a plain language reading of
the Statute meant that Oceanic liable for the entire 4 years, but they
felt that was an absurd result,
and agreed that the penalty period was within the discretion of the
If assessed over a 4 year
period, Oceanic would owe Griffin almost $300k!
The US Supreme Court reversed
and said that Oceanic was liable for 4 years worth of penalties.
The US Supreme Court looked
at the plain language of the
Statute and found that nothing granted any discretion to the courts to
chose the period of days by which the payment was to be calculated.
The Court looked to the purpose of the Statute and found that a literal
application would not thwart its obvious purpose. In fact, the legislative
history implies that this is exact
sort of situation that Congress was trying to remedy.
The Court recognized that
there are situations where a law shouldn't be interpreted in a certain
way because there would be an absurd result. But this result isn't absurd, even though
the punishment seems harsh.
The Court looked to the legislative
history of the Statute. At first, it
had a limit of 10 days, but it was then amended to remove the limit.
That implied that Congress intended the penalty to apply for an unlimited
In addition, the term
"not to exceed 10 days"
implied that the courts had some discretion. However, that was removed,
implying that the courts did not have any discretion anymore.
The US Supreme Court
recognized that the damages awarded by the Statute were not meant to be
merely compensatory, they were meant to be punitive. Therefore it was
not an absurd result to find that
Oceanic's penalties added up to a lot more money than the original amount
they owed Griffin.
In a dissent it was argued
that there are a number of contrary precedents that give discretion to the
courts. In addition, since Congress has never tried to remove this
discretion implies that Congress liked that interpretation. (aka ratification
Ratification by silence is a pretty weak argument. There are many
reasons why Congress doesn't act to clarify a judicial interpretation.