A federal appeals court has dismissed claims of false imprisonment and intentional infliction of emotional distress filed by crew members who were confined aboard a Celebrity Cruises vessel during the initial stages of the COVID-19 pandemic. The 11th U.S. Circuit Court of Appeals ruled in favor of the cruise line, concluding that the company’s actions did not constitute outrageous behavior. This decision stems from a lawsuit initiated by Filipino crew members who sought to return home but were restricted due to health protocols implemented globally.
In early 2020, as the pandemic unfolded, the global cruise industry came to a halt to prevent the spread of the virus. Ryan Maunes Maglana and Francis Karl Bugayong, employees on the Millennium ship, found themselves unable to disembark despite passengers being allowed to leave in Singapore. Subsequently, the Centers for Disease Control and Prevention (CDC) issued a "no sail order," prohibiting further operations from U.S. ports. Consequently, numerous Filipino crew members, including Maglana and Bugayong, remained onboard while the ship anchored off the coast of San Diego.
During this period, an incident involving the unauthorized consumption of alcohol led to the termination of both plaintiffs. However, they continued to be confined on the ship until May 2020 when Celebrity Cruises complied with federal repatriation protocols. Despite their eventual return home via a chartered flight, Maglana initiated legal proceedings alleging false imprisonment among other grievances. Later joined by Bugayong, the suit encompassed claims of emotional distress due to prolonged confinement.
Judge Jose E. Martinez previously dismissed these allegations in 2023, citing arbitration for other matters such as unpaid wages. On appeal, the three-judge panel upheld this dismissal, emphasizing that Celebrity Cruises adhered to CDC guidelines once restrictions permitted repatriation efforts. The court acknowledged the unprecedented challenges faced by both the crew and the cruise line amid rapidly evolving circumstances.
The ruling highlights the complexities encountered during the pandemic, balancing public health mandates with individual rights. While acknowledging the hardships endured by Maglana and Bugayong, the court emphasized that Celebrity Cruises acted within acceptable parameters given the constraints imposed by global health crises. This case underscores the broader implications of crisis management in multinational industries under extraordinary conditions.