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 later.
  • 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 appealed.
    • 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 years!).
  • The Appellate Court affirmed. Griffin appealed.
    • 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 courts.
      • 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 time.
      • 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 by silence).
    • Ratification by silence is a pretty weak argument. There are many reasons why Congress doesn't act to clarify a judicial interpretation.