Justia Admiralty & Maritime Law Opinion Summaries

A passenger aboard a cruise ship alleged that, after becoming inebriated, she was separated from her friends and ended up in a maintenance closet with a crewmember. She stated that she was held against her will and sexually assaulted. Both she and the crewmember gave differing accounts of the incident to FBI agents: she could not recall if she consented to sexual conduct, while the crewmember claimed it was consensual and that he did not know she was intoxicated. The FBI investigator ultimately concluded the encounter was consensual, and prosecutors declined to bring criminal charges.The passenger brought suit in the United States District Court for the Southern District of Florida asserting claims including false imprisonment and sexual assault. In pretrial proceedings, the district court granted her motion for partial summary judgment on the issue of false imprisonment liability, finding that the cruise line had not produced admissible evidence to create a dispute of material fact. The district court excluded the FBI reports as hearsay. At trial, the district court instructed the jury that the cruise line was already liable for false imprisonment and limited the ability of the defendant to challenge the factual basis for that claim. The jury found the cruise line liable for sexual assault but rejected the negligence and intentional infliction of emotional distress claims, awarding over $10 million in damages.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting partial summary judgment on false imprisonment and in excluding the FBI investigator’s conclusions, which were admissible under the public records exception to the hearsay rule. The appellate court reversed the partial summary judgment on the false imprisonment claim, vacated the judgment as to the false imprisonment and sexual assault claims, and remanded for a new trial on those claims. The negligence and intentional infliction of emotional distress claims remain resolved in favor of the cruise line. View "Doe v. Carnival Corporation" on Justia Law

A group of commercial fishers and buyers of South Atlantic red snapper challenged a regulation issued by the National Marine Fisheries Service. This regulation, under the South Atlantic Snapper-Grouper Fishery Management Plan, established an annual catch limit for red snapper based solely on “landings” (fish brought ashore), without including “dead discards” (fish that die after being caught and thrown back). The fishers argued that this approach failed to prevent overfishing as required by federal law, since dead discards represent a significant and increasing portion of total red snapper mortality.The United States District Court for the District of Columbia granted summary judgment in favor of the Service. The district court concluded that the D.C. Circuit’s recent decision in A.P. Bell Fish Co. v. Raimondo largely resolved the main legal issues. That precedent had determined that federal law does not require the annual catch limit to directly restrict bycatch, such as dead discards, so long as the regulatory mechanism is designed to prevent overfishing. The district court also found no basis to conclude that excluding dead discards from the enforceable limit made it impossible to address overfishing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. It first rejected the Service’s argument that the case was moot due to a superseding rule (Amendment 59), finding that the fundamental regulatory approach remained unchanged. On the merits, the court concluded that its prior decision in A.P. Bell Fish Co. controlled: the Service’s landings-only annual catch limit does not violate the statutory requirement to specify catch limits at a level that prevents overfishing. The court affirmed the judgment of the district court. View "Slash Creek Waterworks, Inc. v. Lutnick" on Justia Law

The case concerns an accident involving the Adalyn, a 38-foot commercial workboat owned by Michael Quain Neward Pittman and chartered by Hunter Marine Group, LLC. In November 2024, eight employees of Encore Dredging Partners, LLC were aboard the Adalyn during maintenance dredging operations on the Alabama River when the vessel ran aground and struck a steel pipe, resulting in injuries. The employees were performing work under a contract where Hunter Marine provided the vessel and received a daily flat fee from Encore, regardless of its use.Following the incident, the injured Encore employees filed personal injury claims in state court against Hunter Marine and Encore. In May 2025, Hunter Marine and Pittman sought to limit their liability under the federal Limitation of Liability Act of 1851 by filing a petition in the United States District Court for the Southern District of Texas. The district court stayed the state proceedings and ruled on cross-motions for summary judgment. It concluded that the Adalyn was a “covered small passenger vessel” excluded from the Act’s limitation of liability protections and granted summary judgment to the claimants.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s summary judgment decision de novo. The central issue was whether the Adalyn qualified as a “covered small passenger vessel” by carrying “passengers for hire,” given that consideration for carriage had been provided—albeit indirectly—by Encore on behalf of its employees. The Fifth Circuit held that the statute does not require personal payment by the passenger; indirect payment by an employer suffices. Consequently, the court affirmed that the Adalyn was a covered small passenger vessel, making the Limitation of Liability Act inapplicable and upholding the district court’s summary judgment for the claimants. View "Hunter Marine Group v. Gonzalez" on Justia Law

A company applied to construct a deepwater port off the coast of Texas, including a pipeline that would cross the pipeline of another recently approved deepwater port. The relevant federal statute, the Deepwater Port Act of 1974 (DWPA), requires that only one deepwater port be licensed per “application area.” An environmental group, comprised of local residents near the proposed pipeline and tank farm, objected to the approval, claiming that the pipeline should have been included in the application area. Their concerns included increased risks of flooding, pollution, and negative impacts on property value and quality of life.The United States Maritime Administration (MARAD), acting under authority delegated by the Secretary of Transportation, processed the application. Unlike with previous applications for similar projects, MARAD excluded the proposed pipeline from Texas GulfLink’s application area, reasoning that the DWPA gave it discretion to do so. MARAD then approved Texas GulfLink’s application. The environmental group filed a timely petition for review in the United States Court of Appeals for the Fifth Circuit, challenging MARAD’s decision on the basis that it violated the DWPA.The United States Court of Appeals for the Fifth Circuit held that the DWPA requires the application area to encompass the entire deepwater port site, including pipelines located seaward of the high water mark. The court found MARAD’s designation of the application area to be unlawful because, if the pipeline had been properly included, the application area would overlap with that of another approved port, contrary to the DWPA’s requirement. The court granted the petition for review, vacated MARAD’s approval of the application, and remanded the matter for further proceedings. View "Citizens for Clean Air v. Department of Transportation" on Justia Law

A seaman employed by a transportation district suffered injuries while working on a ferryboat. The seaman and his wife initiated a lawsuit against the district, asserting several maritime claims, including negligence under the Jones Act, unseaworthiness, and maintenance and cure. The wife sought damages for loss of consortium based on the injuries her husband sustained, alleging that the vessel’s condition was unsafe and unseaworthy.The Superior Court of San Francisco City and County reviewed the case. The district filed a demurrer challenging the wife’s loss of consortium claim, arguing that neither the Jones Act nor general maritime law allowed such a remedy. The plaintiffs opposed, contending that general maritime law provided for loss of consortium and that the Jones Act did not bar this type of recovery. The trial court sustained the demurrer without leave to amend, concluding that neither the Jones Act nor general maritime law authorizes recovery for loss of consortium in this context.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the decision. On de novo review, the appellate court affirmed the lower court’s ruling. It held that loss of consortium is not available under the Jones Act for non-fatal injuries, as the statute limits recovery to pecuniary loss and authorizes only the injured seaman (not the spouse) to bring a claim. The court also applied the framework from United States Supreme Court cases—particularly The Dutra Group v. Batterton, Miles v. Apex Marine Corp., and Atlantic Sounding v. Townsend—and found no historical basis for allowing loss of consortium under general maritime law for personal injury unseaworthiness claims. The court thus affirmed the dismissal of the loss of consortium claim. View "Simerley v. Golden Gate Bridge Highway and Transp. Dist." on Justia Law

Two individuals, acting as relators on behalf of the United States, brought a qui tam action against several corporate and individual defendants. They alleged that the defendants engaged in a fraudulent scheme to secure fishing endorsements by misrepresenting the citizenship status of the entity applying for those endorsements. This misrepresentation allowed an ineligible non-U.S. entity to obtain endorsements and harvest menhaden, a commercially valuable fish, from U.S. waters. The relators claimed that these actions violated the False Claims Act by inducing federal authorities to issue fishing endorsements based on false information and by enabling the defendants to illegally profit from harvesting fish to which they were not entitled.The United States District Court for the Southern District of New York reviewed the amended complaint and granted the defendants’ motion to dismiss. The court found that the relators could not demonstrate that defendants made a claim for property as required under several subsections of the False Claims Act. It also concluded that the relators failed to show the defendants avoided or decreased any established obligation to pay money to the United States, as necessary for a reverse false claim. The district court further denied the relators’ request for leave to file an additional amended complaint.The United States Court of Appeals for the Second Circuit considered the relators’ appeal. The court held that wild fish in public waters are not “property” under the False Claims Act, foreclosing the first three causes of action. It also determined that unassessed civil penalties for alleged violations of the American Fisheries Act do not constitute an “obligation to pay” under the Act, defeating the reverse false claim. Finally, the Second Circuit concluded the district court did not abuse its discretion in denying leave to amend, and affirmed the district court’s judgment. View "United States ex rel. Chiles v. Cooke Inc." on Justia Law

Coast Guardsmen intercepted two stateless vessels in international waters, each carrying large quantities of cocaine traveling from Colombia to Mexico. Alonso Pineda-Torres, a Colombian citizen and resident, was involved in planning and preparing these smuggling operations, including paying crewmembers and assisting with a launch from Colombia. After his extradition to the United States, he was indicted under the Maritime Drug Law Enforcement Act for conspiracy to distribute and possess cocaine on a vessel subject to U.S. jurisdiction.In the United States District Court for the Middle District of Florida, Pineda-Torres initially pleaded not guilty, but later entered a plea agreement, admitting involvement in the operation. He moved to dismiss the indictment, arguing the court lacked jurisdiction because his conduct occurred abroad and he was not captured in international waters. The district court denied his motion, and he subsequently pleaded guilty.The United States Court of Appeals for the Eleventh Circuit reviewed the constitutionality of the statute as applied to Pineda-Torres. He argued the statute was invalid because his acts lacked a nexus to the United States and occurred solely in Colombia. The Eleventh Circuit rejected these arguments, relying on its precedent that the Act’s extraterritorial reach is supported by universal and protective principles, and that no nexus to the United States is required. The court held that, even if the Felonies Clause alone did not provide authority, the Necessary and Proper Clause empowered Congress to criminalize conspiracies to commit drug trafficking on the high seas, including land-based conduct like Pineda-Torres’s. Accordingly, the Eleventh Circuit affirmed the conviction, holding Congress had constitutional authority to punish this kind of conspiracy involving drug trafficking in international waters. View "USA v. Pineda-Torres" on Justia Law

Two individuals were bowfishing on Lake Guntersville in Alabama when their boat collided with an unmarked, partially submerged duck blind, resulting in severe injuries. The duck blind, built by unknown persons prior to 2007, was affixed to land owned by the Tennessee Valley Authority (TVA), a federally owned corporation. The United States Coast Guard, the U.S. Army Corps of Engineers, and the TVA all have regulatory responsibilities over the lake, which is a navigable waterway. The plaintiffs alleged negligence and wantonness, claiming that the United States and the TVA failed to mark, remove, or warn about the hazard.The plaintiffs filed suit in the United States District Court for the Northern District of Alabama under two statutes: the Suits in Admiralty Act (SAA) and the TVA Act. Defendants moved to dismiss, arguing that the discretionary-function exception from the Federal Tort Claims Act (FTCA) shielded them from liability. The district court granted the motion, finding that the SAA's waiver of sovereign immunity was subject to the FTCA’s discretionary-function exception and that the conduct at issue was discretionary.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal of all claims against the United States, holding that binding circuit precedent recognizes a discretionary-function exception under the SAA, which bars such claims. However, the Eleventh Circuit reversed the dismissal of the claims against the TVA under the TVA Act. The court held that the TVA’s sue-and-be-sued clause is not subject to the discretionary-function exception, allowing the plaintiffs’ claims against the TVA to proceed. The case was remanded for further proceedings against the TVA only. View "Jones v. USA" on Justia Law

In May 2019, a woman was severely injured during a scuba diving trip in Belize after an employee of a Belizean dive shop, who was not a certified dive master, pushed her off a boat owned by the company. As she entered the water, she was caught by the boat’s engaged propellers, causing significant injuries to her foot, ankle, and knee. She, along with her husband and son, filed a lawsuit in the United States District Court for the District of Massachusetts in August 2020, alleging maritime claims and asserting federal jurisdiction. The Belizean company was served under international procedures, and its founder acknowledged receipt. The company did not participate in the proceedings, leading the court to enter a default judgment against it in June 2021, and, after an evidentiary hearing, award over six million dollars in damages in February 2022.After the judgment, the plaintiff sought to enforce it in Belize, resulting in further default proceedings and an order to pay over seven million dollars, with enforcement actions against the company’s assets. The company eventually contested the judgment in Belize, and the Belizean court later set aside its own default judgment. In February 2024, about two years after the original U.S. judgment and nineteen months after the enforcement effort in Belize began, the company first appeared in the Massachusetts case, seeking to vacate the default judgment under Federal Rule of Civil Procedure 60(b)(4), arguing lack of jurisdiction.The United States Court of Appeals for the First Circuit reviewed whether the company’s motion to vacate was timely under Rule 60(c)(1), which requires such motions to be made “within a reasonable time.” Citing recent Supreme Court precedent, the First Circuit held that this timing requirement applies even to claims that a judgment is void for lack of jurisdiction. The court concluded the company’s nearly two-year delay was unreasonable and affirmed the district court’s denial of the motion. View "Flaherty v. Amigos Del Mar LTD." on Justia Law

A man was stopped by South Dakota wildlife conservation officers while boating on the Missouri River between South Dakota and Nebraska in July 2024. The officers noticed possible impairment and, after a field sobriety test, arrested him for boating under the influence and other offenses. The events in question took place near the Nebraska shoreline, beyond the centerline of the river’s designed channel.The defendant moved to dismiss the charges in the Magistrate Court of the First Judicial Circuit, Union County, South Dakota, arguing the state lacked jurisdiction because the incident happened on the Nebraska side of the river. After an evidentiary hearing, the magistrate court found that the arrest occurred on the Nebraska side, and concluded that South Dakota’s statutes giving conservation officers jurisdiction to the furthermost shoreline were preempted by the federally approved 1989 South Dakota-Nebraska Boundary Compact, which fixes the state boundary at the centerline of the Missouri River. The magistrate court dismissed the case for lack of jurisdiction.The State of South Dakota sought appellate review. The Supreme Court of the State of South Dakota first determined that the State’s petition for intermediate appeal was timely and that it had appellate jurisdiction. The Supreme Court held that the magistrate court did not abuse its discretion by receiving testimony and evidence to resolve the jurisdictional issue. The Supreme Court further held that, based on federal law and the 1989 Compact, South Dakota does not have concurrent jurisdiction over the Missouri River beyond the centerline of the designed channel unless there is an agreement or reciprocal legislation with Nebraska, which does not exist. As a result, the Supreme Court affirmed the magistrate court’s order dismissing the charges for lack of jurisdiction. View "State v. Ogden" on Justia Law