McCrea v. United States

Background

A seaman sued over unpaid wages after leaving a ship that had arrived in London on February 26 and later sailed on March 2. He moved for reargument, arguing the Court had misread the record about when he left. For the first time he pointed to an excerpt from the vessel’s log saying he was aboard from the afternoon of February 29 to the morning of March 1. The district court had found he abandoned the ship two days after arrival; the seaman had testified in the record that he left on February 28 and did not intend to return.

Reasoning

The main question was whether the employer’s failure to pay wages was “without sufficient cause.” The Court declined to reweigh the factual evidence now raised for the first time on reargument. It relied on the district court’s finding that the seaman abandoned the vessel and on the seaman’s own repeated testimony that he left on February 28 and did not return. The Court also emphasized that leaving the ship without telling the captain whether he still insisted on payment undermined any inference that withholding wages was unjustified. For these reasons the Court denied the motion for reargument.

Real world impact

The outcome leaves the lower-court finding intact and means the seaman’s claim for those wages fails here. Practically, when a crew member departs without informing the master, a court may accept a finding of abandonment and treat wage withholding as having sufficient cause. The decision enforces the specific factual ruling in this case and denies further reconsideration.