United States / 23 September 2011 / United States, U.S. Court of Appeals, Eleventh Circuit / Jane Doe v. Princess Cruise Lines, LTD., a foreign corporation, d.b.a. Princess Cruises / 10–10809
| Country | United States |
| Court | United States, U.S. Court of Appeals, Eleventh Circuit |
| Date | 23 September 2011 |
| Parties | Jane Doe v. Princess Cruise Lines, LTD., a foreign corporation, d.b.a. Princess Cruises |
| Case number | 10–10809 |
| Applicable NYC Provisions | II | II(3) |
| Source |
online: PACER |
| Languages | English |
| Summary | The Plaintiff-Appellee, Jane Doe (“Doe”), sued her employer the Defendant-Appellant, Princess Cruise Lines, after being sexually assaulted during non-work hours at a party on Princess Cruise Lines’ ship. Doe alleged ten claims against Princess Cruise Lines, some of which the District Court characterized as maritime law claims and others it characterized as common law tort claims. Princess Cruise Lines sought to compel arbitration of Doe’s claims based on an arbitration agreement in her employment contract which encompassed “any and all disputes, claims, or controversies whatsoever […] relating to or in any way arising out of or connected with” the employment agreements or the services Doe performed for Princess Cruise Lines. The United States District Court for the Southern District of Florida refused to compel arbitration of any of Doe’s claims on the basis that some her claims did not fall within the scope of the parties’ arbitration agreement. Princess Cruise Line appealed. The United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s decision to deny arbitration of some of Doe’s claims but reversed it with respect to the others. The Court held that although the plain language of the arbitration provision was broad, it imposed the limitation that, to be arbitrable, the dispute between Doe and Princess Cruise Lines must relate to, arise from, or be connected with her employment agreements or the employment services that she performed. In other words, the tort or breach in question must have been an immediate, foreseeable result of the performance of her contractual duties. Thus, the Court concluded that Doe’s general and statutory maritime law claims, which derived from her status as a seaman within Princess Cruise Lines employ, fell within the scope of the arbitration agreement and were subject to arbitration. However, the Court found that Doe’s common law tort claims were not dependent on the parties’ employment relationship and were therefore not within the scope of issues that the parties had intended to arbitrate. Accordingly, the Court found it appropriate to compel arbitration of some but not all of Doe’s claims. |
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Attachment (1)
 Original Language Adobe Acrobat PDF |
