Vaughan v. Atkinson

Mr. Vaughan (plaintiff) was a seaman employed on a vessel owned by American Waterways Corporation, operated by National Shipping and Trading Corporation, and mastered by Mr. Atkinson (the vessel parties) (defendants). Atkinson gave Vaughan leave to have a medical examination at an on-shore hospital. The hospital admitted Vaughan for several months on suspected tuberculosis. The hospital then discharged Vaughan but continued treating him in an outpatient capacity for over two years until ultimately deeming him fit to return to duty. During this two-year period, Vaughan sought maintenance and cure from the vessel parties. However, the vessel parties made no sincere attempt to investigate Vaughan’s request and ultimately declined to respond to it at all. To obtain his maintenance and cure benefits, Vaughan was forced to hire a lawyer on contingency to sue the vessel parties. Also, because Vaughan was not receiving any maintenance payments, he was forced to work as a taxi driver to make ends meet during the period he was supposed to be recovering from his illness. Vaughan sued the vessel parties not only for the unpaid maintenance and cure payments but also for damages incurred because of their failure to pay. The sought damages included attorney’s fees. The district court denied the damages claim. On the maintenance and cure claim, the district court awarded Vaughan maintenance but reduced the award by the wages Vaughan earned as a taxi driver. The court of appeals similarly held that Vaughan was not entitled to attorney’s fees and affirmed the district court’s reduction of Vaughan’s maintenance benefits by his taxi-driving earnings. The United States Supreme Court granted certiorari.