Multi-Front Admiralty Seaman Wage Enforcement & Civil Rights Pretext Litigation
This portal compiles a turn-key, document-verified litigation package for Solomon, Saltsman & Jamieson against NCL (Bahamas) Ltd. and its medical contractor Anderson/Kelly Associates.
Immediate Counsel Actions:
| Cause of Action | Governing Statute | Liability Exposure |
|---|---|---|
| Maritime Wage Lien | 46 U.S.C. § 10313 | $2,300 base + $200/day compounding + Vessel Arrest |
| ADA Title I / FCRA | 42 U.S.C. § 12101 / § 1981a | $300,000 Max Cap + Back/Front Pay + Fees |
| Detrimental Reliance | Common Law / Tort | Lost property replacement + Lease damages |
| False Imprisonment | Admiralty Tort | Compensatory & Punitive damages (Gangway) |
| USDOL Audit | FLSA / Federal Wage | Subpoena for Breakaway payroll & deductions |
Under federal maritime law, when seaman wages are withheld without sufficient cause, the vessel owner/operator is subject to a mandatory daily penalty of two days' wages for every day payment is delayed:
| Contract Monthly Salary: | $3,000.00 / month |
| Daily Salary Rate: | $100.00 / day |
| Statutory Daily Penalty Multiplier (2x): | $200.00 / day |
| Gross Wages Paid on Sign-off (7 days): | $700.00 |
| Unpaid Base Monthly Salary Balance: | $2,300.00 |
Under Supplemental Admiralty Rule C, a seaman's wage lien is a preferred maritime lien ranking above ship mortgages and commercial obligations.
When the verified complaint and motion for arrest warrant are filed with the U.S. Marshals Service, NCL must either post a cash bond or letter of undertaking (LOU) before the ship can clear port. This forces corporate general counsel in Miami to engage immediately.
NCL summarily fired Plaintiff alleging he concealed a pre-existing "anxiety" condition with intent to defraud. This pretext collapses under three unassailable facts:
Under ADA Title I regulations, an employer cannot disqualify a worker without an individualized assessment based on reasonable medical evidence. Anderson/Kelly manager Lisa admitted on a recorded call that they never perform this assessment:
David Adams: "...I'm trying to figure out how come you guys did not take that authorization form and get my medical history faxed over because that would show I've never been diagnosed with anxiety?"
David Adams: "Well, they even showed me on the ship, they were like, well, you signed a full medical release authorization form for all of your psychological records..."
This dispute extends far beyond withheld paychecks. In reliance upon a 6-month contract through March 2027, Plaintiff made irreversible life sacrifices that NCL’s bad-faith discharge completely shattered:
| Surrender of Residence: | Plaintiff surrendered his apartment lease and home in reliance on shipboard deployment. |
| Disposal of Possessions: | With no long-term storage and scheduled for 6 months at sea, Plaintiff gave away, sold at a loss, or discarded furniture, appliances, and personal belongings. |
| Induced Domestic Homelessness: | NCL dumped Plaintiff at the pier with only ~$633 in hand, withholding his earned $2,300, leaving him effectively homeless on domestic soil. |
Because Norwegian Cruise Line Holdings Ltd. employs thousands of employees worldwide (well above the 500+ threshold), Defendant sits in the highest statutory damage tier under federal law:
| Damage Category | Legal Authority | Potential Recovery |
|---|---|---|
| Compensatory & Punitive Cap | 42 U.S.C. § 1981a(b)(3)(D) | $300,000.00 |
| Seaman Statutory Penalty | 46 U.S.C. § 10313(g) | $6,100.00+ (Compounding) |
| Lost Wages (Back & Front Pay) | 42 U.S.C. § 2000e-5(g) | Contract balance + Prejudgment int. |
| Statutory Attorney's Fees | 42 U.S.C. § 12205 | Full Fee Shifting to NCL |
Docket Status: Formally lodged on Friday, October 2, 2026 at 3:10 PM EDT.
| Agency: | U.S. Department of Labor (WHD) |
| Thread Reference ID: | thread-f:1877966276108026488 |
| Originating Address: | DOLWHD-ContactUs@dol.gov |
| Official Proof Receipt: | DOL_Filing.pdf |
Targeting NCL shoreside payroll for improper proration of fixed monthly salaries and unauthorized flight deductions under Section 15.
Docket Status: Formally submitted on Friday, October 2, 2026 at 3:38 PM EDT.
| Agency: | Florida Commission on Human Relations / EEOC Miami |
| Respondent: | Norwegian Cruise Line / Norwegian Breakaway (Miami-Dade) |
| Bases Charged: | Disability / Handicap & Retaliation |
| Official 9-Page Charge: | EEOC_FILING.pdf |
Preserves 365-day state statute and 180/300-day federal EEOC window, paving way for federal court right-to-sue.
All primary exhibits are digitally cataloged with verified file links:
