Ellenwood, et al. v. Exxon Shipping Co.

Case Date: 01/14/1993
Court: United States Court of Appeals
Docket No: 92-1473


January 14, 1993
UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT
____________________

No. 92-1473

THEODORE M. ELLENWOOD, ET AL.,

Plaintiffs, Appellees,

v.

EXXON SHIPPING CO.,

Defendant, Appellant.

____________________
STATE OF MAINE,

Intervenor.

_____________________

No. 92-1474

THEODORE M. ELLENWOOD, ET AL.,

Plaintiffs, Appellants,

v.

EXXON SHIPPING CO.,

Defendant, Appellee.
____________________
STATE OF MAINE,

Intervenor.

____________________

APPEALS FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE

[Hon. D. Brock Horny, U.S. District Judge]
___________________

____________________

Before

Breyer, Chief Judge,
___________
Coffin, Senior Circuit Judge,
____________________
and Cyr, Circuit Judge.
_____________

____________________

Peter Bennett with whom Daniel W. Bates was on brief for the
______________ ________________
Ellenwoods.
Thomas D. Warren, Deputy Attorney General, with whom Michael E.
_________________ __________
Carpenter, Attorney General, was on brief for the State of Maine.
_________
Robert M. Hayes with whom Charles G. Bakaly, Jr., Richard G.
________________ ________________________ __________
Moon, and Linda D. McGill were on brief for Exxon Shipping Company.
____ _______________
____________________
____________________






COFFIN, Senior Circuit Judge. Shortly after the Exxon
_____________________ _____

Valdez struck a reef off the Alaskan coast in 1989, defendant
______

Exxon Shipping Company adopted a new policy barring any employee

who had ever participated in an alcohol rehabilitation program

from holding designated jobs within the company. Pursuant to

this policy, plaintiff Theodore Ellenwood, who had no connection

to the Valdez incident, was removed from his position as chief
______

engineer of another Exxon oil tanker, the Exxon Wilmington.
_________________

Ellenwood voluntarily had entered, and successfully had

completed, a month-long alcohol rehabilitation program a year

before the Valdez accident. Despite his concerns about his
______

drinking, Ellenwood never had had an on-the-job problem with

alcohol. A psychiatrist who examined Ellenwood in connection

with this case concluded, in fact, that he had never been an

alcoholic. See Tr. Vol. V, at 133.
___

Relying primarily on the company's previous written policy

that "[n]o employees with alcoholism will have their job security

or future opportunities jeopardized due to a request for help or

involvement in a rehabilitation effort," Ellenwood and his wife

brought suit against Exxon alleging tort and contract claims as

well as violations of state statutes prohibiting discrimination

against the handicapped.1 Ellenwood ultimately received a

____________________

1 The complaint set forth the following causes of action:
breach of contract (Count I); breach of a duty of good faith
arising out of Exxon's use of confidential information concerning
Ellenwood's alcohol treatment as a basis for removing him (Count
II); estoppel arising out of Exxon's representations and promises
(Count III); wrongful discharge in violation of the public policy
promoting responsible treatment of alcoholism (Count IV);

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judgment for $677,648 on his contract and promissory estoppel

causes of action.

In these appeals, both sides contend, inter alia, that the
_____ ____

district court committed legal error in defining the actionable

counts. Ellenwood claims the judge eliminated too many claims on

various legal grounds, depriving him of additional relief, while

Exxon claims that the court allowed too many counts to be

tried.2 We affirm most of the court's rulings. We conclude,

however, that the district court overestimated the preemptive

effects of admiralty law and the Rehabilitation Act of 1973, 29

U.S.C. 701-796, and, accordingly, we must remand for trial on

Ellenwood's state statutory claims of handicap discrimination.3


____________________

discrimination against the handicapped contrary to various state
laws (Count V); misrepresentation over the career consequences of
seeking alcohol treatment (Count VI); intentional and negligent
infliction of emotional distress on both Ellenwoods in ending
Ellenwood's career and disseminating confidential information
concerning his condition (Counts VII and VIII); defamation in
removing Ellenwood from his position as chief engineer (Count
IX); invasion of privacy in the manner in which Exxon obtained
the information about Ellenwood's treatment and disclosed it
(Count X); invasion of privacy in placing Ellenwood in a false
light (Count XI); invasion of privacy in publicizing confidential
information (Count XII); Mrs. Ellenwood's loss of consortium
(Count XIII); and punitive damages (Count XIV).

2 This court granted the State of Maine provisional
permission to intervene on the issue of whether Ellenwood's claim
based on the Maine Human Rights Act, 2A Me. Rev. Stat. Ann. tit.
5, 4571-72 (Supp. 1992), is preempted by federal law.

3 The complaint referred to statutes in Maine, New Jersey
and Texas, and we offer no view as to the applicable law. We
note, however, that the district court applied Texas law to Count
XII of the complaint, which alleged an invasion of privacy. See
___
Memorandum of Decision, Oct. 28, 1991.

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I. Preemption and the Rehabilitation Act4
_____________________________________

A. Background
__________

Section 503 of the Rehabilitation Act of 1973, 29 U.S.C.

793, requires any contract with the federal government in excess

of $2,500 to include a provision obligating the federal

contractor to "take affirmative action to employ and advance in

employment qualified individuals with handicaps." 29 U.S.C.

793(a). Any handicapped individual who believes a contractor has

failed to comply with this provision may file a complaint with

the Department of Labor, which must conduct an investigation and

take appropriate action. 29 U.S.C. 793(b). Regulations

promulgated pursuant to 503 specify a detailed administrative

enforcement mechanism for its breach. See 41 C.F.R. 60-741.1-
___

741.32 (1991). The Department's Office of Federal Contract

Compliance Programs (OFCCP) is empowered, for example, to seek

injunctive relief in court, terminate or cancel a contract, or

bar a contractor from receiving future contracts. 41 C.F.R.

60-741.28(b)-(e) (1991). It also may seek such remedies as back

pay and reinstatement for affected employees. See Dep't of Labor
___ ______________

v. Texas Indus., Inc., 47 Fair Empl. Prac. Cas. (BNA) 18, 28
___________________

(Dep't Labor 1988). See Howard v. Uniroyal, Inc., 719 F.2d 1552,
___ ______ ______________

1559 (11th Cir. 1983) (detailing enforcement procedures).

In a motion for summary judgment, Exxon, which is a federal

contractor, argued that 503 preempts virtually all of


____________________

4 Our review of the district court's preemption decisions,
which were rulings of law, is plenary.

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Ellenwood's state law claims,5 and that Ellenwood's only

recourse on matters related to his alcohol treatment is the claim

he has filed with the OFCCP. The district court rejected this

contention, finding no evidence that Congress intended the

provision to eliminate conventional state law claims such as

breach of contract, misrepresentation, defamation or infliction

of emotional distress, because these claims "are in no way

related to the federal Rehabilitation Act, any affirmative action

clause in a government contract, or handicap discrimination."

See Memorandum of Decision, Oct. 15, 1991, at 3. The court also
___

ruled, however, that 503 did preempt Count V's direct claim of

discrimination on the basis of handicap in violation of various

state statutes, and Count IV's common law claim that Ellenwood's

discharge violated a public policy promoting responsible

treatment of alcoholism.

Neither party is satisfied with this Solomonic division of

the claims. Accordingly, on appeal, we are asked to consider

both Ellenwood's claim that the district court erred in ruling

that 503 preempts Counts IV and V and Exxon's contrary

assertion that the district court erred in finding that the

federal statute does not preempt the contract and promissory

estoppel claims on which Ellenwood received a jury verdict. The

State of Maine joins Ellenwood in arguing that 503 does not

preempt a claim of handicap discrimination brought under its

____________________

5 According to Exxon, only Counts X and XII of the
complaint, charging the company with obtaining and disclosing
private information, survived preemption.

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Human Rights Act, 2A Me. Rev. Stat. Ann. tit. 5, 4571-72 (Supp.

1992). We take up each plea for reversal in turn, following a

brief review of the well established contours of preemption law.

B. Preemption Principles
_____________________

The preemption doctrine is rooted in the Supremacy Clause,

which invalidates state laws that "interfere with, or are

contrary to, the laws of congress." Gibbons v. Ogden, 22 U.S. (9
_______ _____

Wheat.) 1, 211 (1824). See also Cipollone v. Liggett Group,
___ ____ _________ ______________

Inc., 112 S. Ct. 2608, 2617 (1992). A court's sole task in
____

determining whether a state statute is preempted is to ascertain

whether Congress intended the federal law to have such effect.

California Federal Savings & Loan Ass'n v. Guerra, 479 U.S. 272,
________________________________________ ______

280 (1987); Massachusetts Medical Society v. Dukakis, 815 F.2d
______________________________ _______

790, 791 (1st Cir. 1987). Although Congress may articulate its

intent explicitly, see, e.g., Jones v. Rath Packing Co., 430 U.S.
___ ____ _____ ________________

519, 532 (1977), it does not always do so, and the challenge of

preemption law is to identify occurrences of implied preemption.

Preemption by implication may take place in different ways.

First, congressional intent to preempt state law may be

inferred when the scheme of federal regulation in a particular

area is sufficiently pervasive and complex "to make reasonable

the inference that Congress `left no room' for supplementary

state regulation," California Federal Savings & Loan Ass'n, 479
________________________________________

U.S. at 281 (quoting Rice v. Santa Fe Elevator Corp., 331 U.S.
____ ________________________

218, 230 (1947)); see also Dukakis, 815 F.2d at 791. Second, in
___ ____ _______

areas where Congress has not entirely displaced state regulation,
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state law will be deemed preempted to the extent it actually

conflicts with federal law. Such a conflict occurs either

because "`compliance with both federal and state regulations is a

physical impossibility,'. . . , or because the state law stands

`as an obstacle to the accomplishment and execution of the full

purposes and objectives of Congress.'" California Federal Savings
__________________________

& Loan Ass'n, 479 U.S. at 281 (quoting Florida Lime & Avocado
_____________ _______________________

Growers, Inc. v. Paul, 373 U.S. 132, 142-143 (1963) and Hines v.
_____________ ____ _____

Davidowitz, 312 U.S. 52, 67 (1941)). See also O'Brien v.
__________ ___ ____ _______

Consolidated Rail Corp., 972 F.2d 1, 3 (1st Cir. 1992).
_______________________

These alternative avenues to preemption do not mean that

either route is to be chosen lightly. The Supreme Court recently

reiterated the longstanding principle that "`the historic police

powers of the States [are] not to be superseded by . . . Federal

Act unless that [course is] the clear and manifest purpose of

Congress.'" Cipollone, 112 S. Ct. at 2617 (quoting Rice, 331
_________ ____

U.S. at 230). Thus, the presumption is against preemption. Id.
__

at 2618.

C. Applying the Principles
_______________________

1. State handicap discrimination statutes.
______________________________________

Section 503 contains no express language regarding

preemption. Our task, therefore, is to determine whether there

are other indicia of Congressional intent to render state

discrimination laws ineffectual against federal contractors.

Exxon essentially makes a two-pronged argument. First, it cites

legislative history suggesting that Congress sought a uniform
-8-


federal remedy for violations of 503, which would be frustrated

if contractors additionally were subject to varying state laws.

Thus, according to Exxon, Congress must have intended to preempt

state provisions.

Second, Exxon suggests that the detailed nature of the

administrative scheme promulgated under 503 demonstrates

Congress's intent to foreclose other types of remedies against

federal contractors. Exxon maintains that, while Congress has

not fully occupied the field of handicap discrimination, with

respect to federal contractors, it has "`left no room' for

supplementary state regulation," California Federal Savings &
______________________________

Loan Ass'n, 479 U.S. at 281.
__________

In our view, what Exxon offers as proof of an intent to

preempt falls short of the mark. The legislative history on

which the company relies is a single passage in a Senate

Committee Report relating to amendments to the Rehabilitation Act

that were enacted a year after the Act itself. The amendments

made no change in either sections 503 or 504 of the Act,6 but

the Senate Report commented:

It is intended that sections 503 and 504 be
administered in such a manner that a consistent,
uniform, and effective Federal approach to
discrimination against handicapped persons would
result. Thus, Federal agencies and departments should
cooperate in developing standards and policies so that
there is a uniform, consistent Federal approach to
these sections.


____________________

6 Section 504, 29 U.S.C. 794, prohibits discrimination
against the handicapped in federally funded programs, the United
States Postal Service, and in Executive agencies.

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S. Rep. No. 1297, 93d Cong., 2d Sess., reprinted in 1974
_____________

U.S.C.C.A.N. 6373, 6391.

Exxon claims this passage demonstrates that Congress was

seeking an exclusive approach to handicap discrimination by

federal contractors, and that, consequently, it must have

intended 503 to displace parallel state laws governing the same

conduct. Even without regard for the lesser weight accorded this

subsequent history than would be accorded contemporaneous

legislative comments, see Heckler v. Turner, 470 U.S. 184, 209
___ _______ ______

(1985), we believe Exxon has read far too much into the quoted

remarks.

We are persuaded that the passage in no way implicates state

law but instead reflects Congress's concern about the lack of

coordination on the federal level between the two agencies
_______________________

responsible for implementing sections 503 and 504. The Senate

Report continues from the portion quoted above to elaborate on

the agencies' relationship:

The Secretary of the Department of Health, Education,
and Welfare, because of that Department's experience in
dealing with handicapped persons and with the
elimination of discrimination in other areas, should
assume responsibility for coordinating the section 504
enforcement effort and for establishing a coordinating
mechanism with the Secretary of the Department of Labor
to ensure a consistent approach to the implementation
of sections 503 and 504.

S. Rep. No. 1297, 93rd Cong., 2d Sess., reprinted in 1974
____________

U.S.C.C.A.N. 6373, 6391. In our view, Congress was calling for a

more uniform and consistent "Federal approach to discrimination
_______

against handicapped persons," id. (emphasis added); nothing in
__
-10-


the passage indicates that it was seeking to eliminate any role

for state law. See D'Amato v. Wisconsin Gas Co., 760 F.2d 1474,
___ _______ _________________

1482 (7th Cir. 1985) (by insisting on coordination, Congress was

directing "that the two responsible agencies were not to work at

cross purposes or to duplicate each other's efforts") (citation

omitted).

Exxon's second basis for inferring an intent to preempt --

the comprehensive and detailed regulations promulgated under

503 -- is equally unavailing. The fact that Congress has

implemented an extensive regulatory scheme in a particular area

does not lead necessarily to the conclusion that it intended to

displace parallel state remedies. As the Supreme Court stated in

Hillsborough County v. Automated Medical Laboratories, Inc., 471
____________________ ____________________________________

U.S. 707, 716-18 (1985):

To infer pre-emption whenever [a federal agency] deals
with a problem comprehensively is virtually tantamount
to saying that whenever a federal agency decides to
step into a field, its regulations will be exclusive.
Such a rule . . . would be inconsistent with the
federal-state balance embodied in our Supremacy Clause
jurisprudence.

See also R.J. Reynolds Tobacco Co. v. Durham County, 479 U.S.
___ ____ ___________________________ ______________

130, 149 (1986) (preemption should not be inferred simply because

federal agency's regulations are comprehensive). Exxon cites

nothing in the state provisions that would make compliance with

both state law and the detailed 503 scheme a "physical

impossibility," Florida Avocado & Lime Growers, 373 U.S. at 143,
_______________________________

and, in the absence of other evidence of preemptive intent, there

is no basis for displacing the state law.
-11-


In accepting Exxon's argument that Congress intended to

preempt state anti-discrimination remedies against federal

contractors, the district court relied entirely on the analysis

of the Eleventh Circuit in Howard v. Uniroyal, Inc., 719 F.2d
______ _______________

1552 (1983). In Howard, the plaintiff had alleged a claim under
______

Alabama law as a third party beneficiary of the 503 affirmative

action clause contained in contracts between his employer and the

federal government.

The Eleventh Circuit rejected this claim. It held that

state contract remedies could not be used to enforce 503

essentially for the reasons Exxon has offered to us in support of

its preemption argument. Emphasizing the Senate Report's

reference to federal uniformity and the comprehensiveness of the

503 administrative scheme, the Howard court found it
______

"reasonable to infer that Congress left no room in section 503(b)

for state contract actions to supplement it," id. at 1559. The
__

court concluded that allowing the plaintiff to broaden

enforcement of the affirmative action clause by means of state

law could frustrate directly the specific scheme designed by

Congress, allowing a private claim through the back door that

couldn't come through the front door.

An inference of preemption was further warranted, the court

held, because Congress's substantial interest in enforcing the

affirmative action clause -- determining appropriate terms,

conditions and remedies -- was "more substantial" than the
-12-


state's interest in providing a remedy for third party

beneficiaries seeking to enforce the same clause. Id. at 1561.
__

We believe Exxon and the district court have relied unwisely

on Howard, which differs from this case in a crucial respect.
______

There, the plaintiff sought to use state law to enforce 503

itself; the court ruled that Congress intended the federal

administrative remedy to be the plaintiff's sole means of

enforcing the affirmative action clause. Here, however,

Ellenwood is seeking to enforce not 503, but independent

obligations created by state anti-discrimination statutes.

The claim in this case does not threaten the uniformity of
__________

the 503 system. Rather, the issue here is one of

compatibility, specifically, whether there is any basis for
_____________

inferring that Congress believed an independent state remedy

could not co-exist with the 503 system. Howard is not helpful
______

in this context. In the employment discrimination field,

Congressional enactments "have long evinced a general intent to

accord parallel or overlapping remedies against discrimination."

Alexander v. Gardner-Denver Co., 415 U.S. 36, 47 (1974). See
_________ ___________________ ___

also California Federal Savings & Loan, 479 U.S. at 282-83;
____ ___________________________________

Kremer v. Chemical Construction Corp., 456 U.S. 461, 468-69
______ ____________________________

(1982); Muncy v. Norfolk and Western Railway Co., 650 F. Supp.
_____ ________________________________

641, 644 (S.D.W. Va. 1986) (ruling that 503 does not preempt

state human rights act). Nothing in 503, which is focused

narrowly on the contractual requirement for an affirmative action
-13-


clause, provides a basis to infer a departure from that

traditional approach.

In addition, several references in 503's legislative

history suggest that, rather than seeking to preempt state law

through comprehensive legislation, Congressional leaders

recognized that the federal statute was a modest one:

"We are just beginning to do too little as the
dimension of the problem grows in geometric
proportion." Congressman Vanik, Congressional Record -
- House 18137 (June 5, 1973); "[W]e have only begun to
scratch the surface in meeting the needs of our
disabled fellow citizens." Congressman Brademus [sic],
Congressional Record -- House 30149 (September 18,
1973); "I do not consider [this bill] to be a perfect
bill, or in all honesty, even an adequate bill."
Senator Randolph, Congressional Record -- Senate 34586
(July 18, 1973).7

Raytheon Co. v. Fair Employment and Hous. Comm'n, 46 Fair Empl.
____________ _________________________________

Prac. Cas. (BNA) 1089, 1099 (Cal. Sup. Ct. 1988), aff'd, 212 Cal.
_____

App. 3d 1242, 261 Cal. Rptr. 197 (2d Dist. 1989).

A year later, in the Rehabilitation Act Amendments of 1974,

Congress added a provision requiring state agencies that

administer programs funded under the Act to take affirmative

action to employ and advance qualified handicapped individuals

who are covered under 503. See Senate Report No. 1297,
___

reprinted in 1974 U.S.C.C.A.N., at 6391-92. The Senate Committee
____________

Report noted that these agencies "are expected to adopt strong

affirmative action programs which are at least equivalent to
_________

those now being developed for Federal agencies." Id. at 6392
__

____________________

7 Both Congressman Brademas and Senator Randolph were among
the managers of the legislation. See Conf. Rep. No. 500, 93rd
___
Cong., 1st Sess., reprinted in 1973 U.S.C.C.A.N. 2143, 2154.
____________

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(emphasis added). These comments, although referring to

administering agencies rather than federal contractors,

nevertheless suggest that Congress both acknowledged the role

played by states in the area of handicap discrimination and

assumed that states might choose to provide different -- greater

-- protection than that afforded by the federal government. See
___

Raytheon, 46 Fair Empl. Prac. Cas., at 1099.8
________

Finally, we note that, in the recent Americans with

Disabilities Act of 1990, 42 U.S.C. 12101-12213, which amended

the Rehabilitation Act and extended remedies for handicap

discrimination against many more private employers, Congress

stated explicitly that the legislation did not "limit the

remedies, rights, and procedures of any . . . law of any State .

. . or jurisdiction that provides greater or equal protection for

the rights of individuals with disabilities than are afforded by

this chapter." 42 U.S.C. 12201(b). While this provision

obviously can have no effect on our view of Congressional intent

in 1973, it is a particularly pertinent example of Congress's

historical practice of allowing overlapping remedies for

employment discrimination.9

____________________

8 We ackowledge that this post-enactment legislative history
is of less weight than contemporary commentary, but it is
nevertheless of some significance. See, e.g., Heckler, 470 U.S.
___ ____ _______
at 209; Cannon v. University of Chicago, 441 U.S. 677, 686-687,
______ _____________________
n.7 (1979).

9 The absence of a provision disclaiming preemption from the
Rehabilitation Act of 1973 does not demonstrate, in the absence
of other evidence, an intent to foreclose state remedies.
Because of its far more comprehensive reach, the ADA is likely to
have appeared more preemptive than the earlier legisation.

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Exxon attempts to distance this case from the tradition of

overlapping remedies in two ways. First, it asserts that

Congress has a unique interest in regulating federal contractors

and, second, it claims that the area of handicap discrimination

requires an extraordinary balancing of competing interests that

distinguishes it from other types of employment discrimination,

such as those involving race, gender or age. In the handicap

discrimination field, Exxon maintains, the possibility of

conflicting judgments is much greater because courts in different

jurisdictions could reach widely disparate conclusions on such

basic questions as what constitutes a "handicap" and which

handicapped persons are "qualified" to hold particular positions.

Restricting individuals to their 503 remedy would ensure that a

federal contractor doing business in more than one state would

face uniform obligations nationwide.

We think it unlikely that Congress has a special interest in

immunizing federal contractors from obligations otherwise

applicable to them under state handicap discrimination statutes.

These companies may do only $2,500 in business with the federal

government, with the bulk of their enterprise devoted to commerce

within a single state. This division gives the state a

substantial interest in protecting the employment interests of

its handicapped citizens. The developing nature of the issues

raised in the field of handicap discrimination strikes us as


____________________

Congress evidently made the sensible decision to avoid confusion
by including an express provision.

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insufficient justification for excusing these employers from

obligations imposed on others who differ only in that the federal

government is not one of their customers.

Moreover, Exxon's obligation is not simply to identify

reasons why Congress might have departed from its usual practice,

but to demonstrate a reasonable basis for inferring that Congress

did, in fact, intend to make the federal remedy exclusive in this

single area of employment discrimination law. Exxon has offered

nothing from which we can discern such an intent.

In sum, we find no "clear and manifest" intent on the part

of Congress to preempt state handicap discrimination claims

against federal contractors. Indeed, we find no signals of such

an intent.10

2. Contract and promissory estoppel.
________________________________

In its appeal, Exxon contends that the district court should

have extended its 503 preemption ruling to Ellenwood's contract

and promissory estoppel claims as well. Exxon points out that

these claims allege that the company breached an agreement or

promise not to discriminate on the basis of Ellenwood's

"handicap" of alcohol abuse. Again relying solely on the

uniformity rationale, Exxon argues that all state claims based on

the same assertedly discriminatory conduct are foreclosed by

503.


____________________

10 Our preemption analysis applies as well to Ellenwood's
claim for wrongful discharge based on public policy. We offer no
view, however, as to whether such a claim exists under the
applicable state law.

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Our ruling on the statutory claims also is dispositive here.

We note, however, one instance in which a contract claim based on

statements in a company policy manual may be preempted by 503.

Regulations promulgated under the statute require employers to

post notices of their Rehabilitation Act obligations and of

employee rights under 503 in "conspicuous places." See 41
___

C.F.R. 60-741.4(d). If an employer included such a notice in

its policy manual solely to comply with this regulation, a state

contract claim based on a breach of the manual provision arguably

would be preempted by the federal law. See Arellano v. Amax Coal
___ ________ _________

Co., 56 Fair Empl. Prac. Cas. (BNA) 1519, 1524-25 (D. Wy. 1991).
___

Such a claim, though in the guise of a contract claim based on

the manual, would seem no different from one directly asserting a

breach of 503. A direct claim under 503 unquestionably would

be preempted for the reasons set out in Howard.
______

Exxon does not contend that the statements at issue here

were required by 503. Indeed, such a contention would be

patently unsupportable. Ellenwood's contract and estoppel claims

are not premised on a general notice of Exxon's affirmative

action obligations toward handicapped individuals, but on a very

specific written assurance from the company that it would not

disadvantage employees for seeking treatment for alcoholism.

We therefore hold that the district court correctly

determined that Ellenwood's contract and estoppel claims were not

preempted by 503.
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II. The Role of Admiralty Law
_________________________

Our conclusion that 503 does not preempt Ellenwood's state

statutory and common law claims does not end our inquiry into

whether those claims are foreclosed by federal law. Exxon also

contends that, even if 503 does not preempt them, maritime law

does. We consider this contention first as to the state statutes

and second as to the contract and estoppel claims.

A. State handicap discrimination statutes.
______________________________________

In a brief footnote, the district court observed that, even

if it had erred in its judgment about 503 preemption, the state

handicap discrimination claims nevertheless would be foreclosed

because maritime law, rather than state law, governs all issues

surrounding Ellenwood's employment as a chief engineer on board

ship. The court stated that, "I am not aware of any basis under

maritime law for such a recovery." Memorandum of Decision, Oct.

15, 1991, at 4 n.3.

The district court underestimated the role state law plays

in maritime cases. Supreme Court cases make it clear that courts

in admiralty cases may reach beyond maritime precedents and apply

state laws "absent a clear conflict with the federal [maritime]

law," Askew v. American Waterways Operators, Inc., 411 U.S. 325,
_____ __________________________________

341 (1973). See also Romero v. International Terminal Co., 358
___ ____ ______ ___________________________

U.S. 354, 373-75, 378, n.42 (1959); Just v. Chambers, 312 U.S.
____ ________

383, 391 (1941); Lyon v. Ranger III, 858 F.2d 22, 27 (1st Cir.
____ ___________

1988); 1 S. Friedell, Benedict on Admiralty 112, at 7-36 (7th
______________________

ed. 1991); 14 C. Wright, A. Miller & E. Cooper, Federal Practice
________________
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and Procedure (hereafter Wright & Miller) 3672, at 441-444
_____________ _________________

(1985).

Exxon contends that this is a case of conflict. It asserts

that applying state non-discrimination statutes in an admiralty

case will contravene federal maritime law by undermining that

"most fundamental and long established characteristic of maritime

law: the need for `harmony and uniformity' of that law." Exxon

Brief at 21 (quoting Southern Pacific Co. v. Jensen, 244 U.S.
_____________________ ______

205, 216 (1917)). See also Miles v. Apex Marine Corp., 111 S.
___ ____ _____ __________________

Ct. 317, 322-23 (1990) (noting "`the constitutionally based

principle that federal admiralty law should be "a system of law

coextensive with, and operating uniformly in, the whole

country"'") (quoting Moragne v. States Marine Lines, Inc., 398
_______ __________________________

U.S. 375, 398 (1970) (quoting The Lottawanna, 21 Wall. 558, 575
______________

(1875))); Carey v. Bahama Cruise Lines, 864 F.2d 201, 207 (1st
_____ ____________________

Cir. 1988).

Once again, however, Exxon heralds the need for uniformity

without an appreciation for the boundaries of its relevance. All

state laws, if given effect in admiralty cases, will interfere to

a degree with the uniformity of admiralty law. See 1 Benedict on
___ ___________

Admiralty 112, at 7-36. But when Congress established a
_________

separate admiralty jurisdiction and empowered the judiciary to

develop substantive maritime principles for use nationwide, 14

Wright & Miller 3671, it simultaneously assured that state law
________________

would continue to play some role in maritime affairs through the
-20-


"saving to suitors" clause.11 This provision allows plaintiffs

to pursue, in addition to maritime relief, ordinary civil

remedies provided by state law, so long as they do not conflict

with the national substantive maritime law. See 14 Wright &
___

Miller 3672, at 440-444.

Through the years, the Supreme Court has confirmed that

"[t]he State and Federal Governments jointly exert regulatory

powers" in maritime matters, Romero, 358 U.S. at 374, and it is
______

by now well established that state law is displaced only when it

materially prejudices "the characteristic features of maritime

law," 1 Benedict on Admiralty 112, at 7-36. As we observed in
_____________________

Carey, "the Supreme Court . . . no longer construes the Admiralty
_____

Clause as requiring `rigid national uniformity in maritime

legislation.'" 864 F.2d at 207 (citation omitted). See also Lyon
___ ____ ____

v. Ranger III, 858 F.2d at 27; G. Gilmore & C. Black, The Law of
__________ ___________

Admiralty, at 49-50 (2d ed. 1975). In other words, a state law
_________

claim should not be dismissed simply because it would result in

differing remedies for plaintiffs in different parts of the

country; such a claim is foreclosed only if the state law in

question frustrates a fundamental tenet of admiralty law. See
___

____________________

11 The Judiciary Act of 1789 granted the federal trial
courts "exclusive original cognizance of all civil causes of
admiralty and maritime jurisdiction," but also reserved to
"suitors, in all cases, the right of a common law remedy, where
the common law is competent to give it." See Southern Pacific
___ ________________
Co., 244 U.S. at 215-216. In its present form, see 28 U.S.C.
___ ___
1333(1), the clause gives the district courts original
jurisdiction, "exclusive of the courts of the States," of: "Any
civil case of admiralty or maritime jurisdiction, saving to
suitors in all cases all other remedies to which they are
otherwise entitled."

-21-


Steelmet, Inc. v. Caribe Towing Corp., 779 F.2d 1485, 1488 (11th
_______________ ___________________

Cir. 1986).

For example, in Carey, 864 F.2d at 207, we held that a
_____

Massachusetts rule barring tort recovery when a plaintiff is more

than 50 percent negligent could not be applied in a maritime case

because "[o]ne of the essential and longstanding features of

substantive admiralty law is that contributory negligence can be

considered only in mitigation of damages." The rule wholly

foreclosing recovery is "`completely incompatible' with modern

admiralty practice." Id. (quoting Pope & Talbot, Inc. v. Hawn,
__ ___________________ ____

346 U.S. 406, 409 (1953)).

Although the rule barring state claims only if they directly

conflict with basic maritime principles often requires "a

delicate accommodation of federal and state interests," Carey,
_____

864 F.2d at 207, we have been shown nothing in substantive

maritime law that is even potentially at odds with state human

rights statutes such as those underlying Count IV of Ellenwood's

complaint. Congress's only legislation in the area of

handicapped rights has not been directed at maritime cases and,

as discussed supra, its legislation did not preempt state
_____

remedies. We find no indications that the absence of substantive

maritime law governing issues concerning individuals with

handicaps reflects a federal interest in protecting maritime

employers from such obligations. See 1 Benedict on Admiralty
___ ______________________

112, at 7-37. To the contrary, the Rehabilitation Act's
-22-


applicability to maritime employers demonstrates federal approval

of such obligations.

Thus, the district court's observation that maritime law has

not addressed handicap discrimination specifically is not a

reason to dismiss the state claim but a basis upon which to give

effect to the state provisions. Maritime law historically has

appreciated the leading role of state statutes in creating

additional bases of recovery. In maritime wrongful death cases,

for example, remedies first were provided solely under state law.

See Miles, 111 S. Ct. at 320-23; Moragne v. States Marine Lines,
___ _____ _______ ____________________

Inc., 398 U.S. 375, 397 (1970). When Congress enacted maritime
____

wrongful death legislation in 1920, it provided remedies only

where state law did not. Miles, 111 S. Ct. at 321; Moragne, 398
_____ _______

U.S. at 397-98. State statutes continued to play a primary role

for another fifty years, until the Supreme Court created a

general maritime cause of action for wrongful death. See Miles,
___ _____

111 S. Ct. at 321-323; Moragne, 398 U.S. at 398-402.12
_______

In its reply brief, the State of Maine notes a possible

concern that strict state standards regarding employment of the

handicapped would conflict with the maritime doctrine of

seaworthiness. The State emphasizes, however, that under its

law, any legitimate physical requirements for crew members under


____________________

12 Even today, plaintiffs may invoke state wrongful death
statutes under the saving clause insofar as they involve
accidents in territorial waters and do not conflict with the
substantive principles developed under the maritime wrongful
death doctrine. See Offshore Logistics, Inc. v. Tallentire, 477
___ ________________________ __________
U.S. 207, 227 (1986).

-23-


the seaworthiness doctrine would constitute bona fide

occupational requirements that would provide a defense to claims

brought under the statute. See 2A Me. Rev. Stat. Ann. tit. 5,
___

4572(1) (Supp. 1992). Of course, whether or not a state's

statute specifically included such a defensive provision, vessel

owners obviously could not be held liable for damages under state

anti-discrimination laws when federal maritime principles

required the employer to make the contested employment decision.

In that narrow way, maritime law would be preemptive.

As a general matter, however, we conclude that state human

rights statutes may be applied in maritime cases. Indeed, it

would be anomalous for maritime law, which has always shown "a

special solicitude for the welfare of seamen and their families,"

Miles, 111 S. Ct. at 327, to reject such an employee-sensitive
_____

provision. See also Smith v. Atlas Off-Shore Boat Serv., Inc.,
___ ____ _____ _________________________________

653 F.2d 1057, 1063 (5th Cir. Unit A 1981) (noting "the admiralty

court's protective attitude towards the seaman). "`[C]ertainly

it better becomes the humane and liberal character of proceedings

in admiralty to give than to withhold the remedy.'" Miles, 111
_____

S. Ct. at 327 (quoting Moragne, 398 U.S. at 387 (quoting Chief
_______

Justice Chase in The Sea Gull, 21 F. Cas. 909, 910 (No. 12,578)
____________

(CC Md. 1865))). See also Austin v. Unarco Industries, Inc., 705
___ ____ ______ _______________________

F.2d 1, 6 n.1 (1st Cir. 1983) (state law "is generally referred

to only when it affords greater protection to maritime employees

than that afforded by admiralty law").

B. Contract and promissory estoppel.
________________________________
-24-


Exxon contends that, in allowing the jury to consider

Ellenwood's contract and estoppel claims, the district court

improperly created an exception to the well-established rule that

maritime employment is terminable at will by either party in the

absence of a contract setting a specific term. According to

Exxon, maritime law has "clung tenaciously" to the at-will

principle, and only one narrow exception previously has been

carved from it. In Atlas Off-Shore Boat Serv., 653 F.2d at 1062-
__________________________

63, the court permitted a claim for wrongful discharge when a

seaman was fired for filing a personal injury claim that he was

entitled to file by statute. No additional exceptions should be

allowed to erode the strength of the at-will doctrine, Exxon

argues, since the seaman's rights as an employee already are well

protected by federal statute. See generally, e.g., 46 U.S.C.
___ _________ ____

10302, 10303, 10313, 10502, 10504, 10505, 10506 (prescribing

procedures governing meals, hours and wages for seamen).

Exxon misperceives the district court's ruling. The court

did not devise a new "wrongful discharge" cause of action on

behalf of Ellenwood. It simply recognized the obvious fact that

-- notwithstanding the general rule that a seaman's employment is

at-will -- a maritime employer may make a contractual agreement

with, or an enforceable promise to, its employees.

In this case, Ellenwood claimed that Exxon had promised that

his job security and future opportunities would not be

jeopardized if he sought treatment for alcoholism. The jury

found that the requirements for establishing a binding obligation
-25-


were met. We see no reason why maritime law would invalidate

this self-imposed obligation.13

Accordingly, we affirm the district court's judgment on the

breach of contract and estoppel claims. See infra Section V.
___ _____

III. Negligent Infliction of Emotional Distress
__________________________________________

The jury awarded Theodore Ellenwood $50,000 and his wife

$25,000 on their claims for negligent infliction of emotional

distress. The district court overturned these verdicts on the

ground that maritime plaintiffs may not recover for negligently

caused emotional damages unless they demonstrate accompanying

physical injury or impact.14 The Ellenwoods presented no

evidence of physical harm.

In granting judgment for defendants, the district court

noted that the Supreme Court in Atchison, Topeka and Santa Fe Ry.
_________________________________


____________________

13 Exxon does not argue that the district court improperly
instructed the jury on the elements necessary to establish a
contract or promissory estoppel claim in these circumstances, and
we therefore do not delve into this issue. See, e.g., Pearson v.
___ ____ _______
John Hancock Mutual Life Ins. Co., No. 92-1684, slip op. (1st
___________________________________
Cir. Nov. 10, 1992) (discussing factors necessary to establish
contract based on employee manual).
We do note that, as Exxon recognizes in its reply brief, a
contract must be "reasonably certain" to be enforceable. See
___
Restatement (Second) of Contracts 33 (1981). An estoppel claim
_________________________________
similarly must be supported by a sufficiently definite promise.
See Santoni v. Federal Deposit Ins. Corp., 677 F.2d 174, 178-79
___ _______ ___________________________
(1st Cir. 1982). Exxon does not -- and, in our view, cannot
reasonably -- argue that its policy statement assuring no adverse
consequences based on alcoholism treatment is insufficiently
definite to support a contract or estoppel claim.

14 The court very prudently allowed the claims to go to the
jury, thus foreclosing the possibility of a later heavy
investment of time and expense in the event that it should render
a judgment notwithstanding the verdict and that we would
disagree.

-26-


Co. v. Buell, 480 U.S. 557, 568 (1987), had raised the