Justia Admiralty & Maritime Law Opinion Summaries

The United States government brought a civil forfeiture action against a luxury superyacht, alleging that it was beneficially owned by a Russian national subject to U.S. sanctions. Two claimants, an individual and his company, asserted that they—not the sanctioned individual—owned the yacht, both legally and beneficially. The government, however, argued that these claimants were mere straw owners holding title on behalf of the sanctioned individual and therefore lacked constitutional standing to contest the forfeiture.The United States District Court for the Southern District of New York held an evidentiary hearing to resolve factual disputes regarding the claimants’ standing. The court found, by a preponderance of the evidence, that the claimants had relinquished all meaningful ownership and control over the yacht through a memorandum of agreement executed in September 2021. As a result, the court concluded that the claimants were only bare title holders, acting as straw owners, and lacked Article III standing to object to the forfeiture. The court granted the government’s motion to strike the claim and entered default and final judgments of forfeiture when no other claims were filed.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Second Circuit affirmed, holding that the claimants’ legal title alone did not establish standing where the evidence showed they retained no substantive ownership interest after the September 2021 agreement. The court also upheld the district court’s exclusion of a hearsay declaration and concluded there was no procedural error in the conduct of the evidentiary hearing. The judgment of forfeiture was affirmed. View "United States v. The M/Y Amadea" on Justia Law

SLT Imports, a New Jersey company, agreed to finance the importation of goods for Krishna Food Corp. from Bikaji Foods International in India, using SAR Transport Systems as the maritime carrier. Under the arrangement, Krishna would pay SAR by drawing from SLT’s bank facility, and SAR was required to release cargo only upon presentation of an endorsed bill of lading (BOL). SLT later discovered that SAR had delivered goods to Krishna without receiving endorsed BOLs, instead accepting letters of indemnity. SLT alleged that SAR breached the contract and committed fraud in the execution by issuing BOLs with terms it did not intend to honor.The U.S. District Court for the District of New Jersey granted SAR’s motion for judgment on the pleadings, dismissing SLT’s breach-of-contract claim as waived and time-barred under the Carriage of Goods by Sea Act (COGSA), and rejecting SLT’s fraud-in-the-execution claim. The District Court found that SLT failed to allege facts establishing fraud in the execution, and that even if it had, the claim was barred by COGSA’s one-year statute of limitations. The Court also held that the deviation doctrine and equitable estoppel did not apply. SLT’s motion for reconsideration was denied.On appeal, the U.S. Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. It held that SLT did not adequately plead fraud in the execution, as the allegations amounted to breach of contract rather than fraud. The Third Circuit further concluded that SLT’s claim was time-barred by COGSA’s one-year limitation period and that neither the deviation doctrine nor equitable estoppel could circumvent this bar. The Court affirmed the judgment of the District Court, including the denial of leave to amend and the denial of reconsideration. View "SLT Imports Inc v. SAR Transport Systems Pvt Ltd" on Justia Law

Havana Docks Corporation, a U.S.-based entity, obtained a usufructuary concession from the Cuban Government in 1928, granting it the right to develop and operate docks at the Port of Havana until 2004. This concession included a government promise of compensation if expropriation occurred before expiration. In 1960, following Fidel Castro’s rise to power, the Cuban Government seized control of the docks without compensating Havana Docks, prematurely terminating its concession. The Foreign Claims Settlement Commission later certified Havana Docks’ loss as approximately $9 million plus interest. Decades later, from 2016 to 2019, four major cruise lines used the Havana docks to transport passengers to Cuba, paying Cuban government-affiliated entities for access.Havana Docks sued the cruise lines under the Cuban Liberty and Democratic Solidarity Act (LIBERTAD Act) in the United States District Court for the Southern District of Florida. The cruise lines argued they could not be liable because Havana Docks’ concession would have expired in 2004 even without confiscation. The District Court disagreed, found for Havana Docks, and ordered each cruise line to pay over $100 million. The United States Court of Appeals for the Eleventh Circuit reversed this judgment, holding that liability under the Act required the defendant’s conduct to interfere with a property interest the plaintiff would have had absent confiscation, and since Havana Docks’ concession would have expired before the cruise lines’ conduct, no liability attached.The Supreme Court of the United States reviewed the case and disagreed with the Eleventh Circuit’s analysis. The Court held that, under the Act, liability attaches to anyone who traffics in physical property confiscated by the Cuban Government, not just property interests. It concluded that the cruise lines’ use of the docks constituted trafficking in confiscated property to which Havana Docks owns a claim, regardless of when Havana Docks’ concession would have expired. The Supreme Court vacated the Eleventh Circuit’s decision and remanded the case for further proceedings. View "Havana Docks Corp. v. Royal Caribbean Cruises, Ltd." on Justia Law

A seaman was severely injured while working on an offshore supply vessel operated by his employer. Following his injury, the employer provided both mandatory and supplemental benefits, including housing and transportation. Six months after the incident, the employer’s executives presented the seaman with an agreement offering continued supplemental benefits in exchange for his commitment to arbitrate any future claims against the company. The agreement included a delegation clause stating that any disputes about the validity, interpretation, or application of the agreement would be resolved by an arbitrator. The seaman signed, acknowledging he had the opportunity to consult an attorney but later alleged he felt pressured and feared losing benefits if he did not sign.The seaman filed suit in the United States District Court for the Eastern District of Louisiana, alleging negligence and seeking a declaration that the agreement and its arbitration provisions were invalid due to fraud, duress, and his medical condition. The employer moved to compel arbitration and to stay the litigation, arguing that the delegation clause required an arbitrator to decide issues of enforceability. The district court denied the motion without prejudice and allowed limited discovery on the enforceability of the agreement, concluding it must decide if a valid arbitration agreement existed.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court erred by failing to enforce the delegation clause. The appellate court found the seaman’s arguments challenged the agreement as a whole, not the delegation clause specifically. Under Supreme Court precedent, such challenges must be resolved by an arbitrator when a valid delegation clause exists and is not directly challenged. The Fifth Circuit vacated the district court’s order and compelled arbitration, remanding for further proceedings consistent with this holding. View "Hill v. Jackson Offshore Holdings" on Justia Law

A Dominican Republic citizen was operating a high-speed vessel in international waters off Puerto Rico with two others when a United States Coast Guard helicopter and cutter approached. After issuing warning shots that failed to stop the vessel, the Coast Guard fired live rounds at the engine, and two bullets struck the plaintiff’s left arm, causing serious, permanent injury. The plaintiff remained on deck for thirty minutes before receiving medical attention and was later airlifted to a hospital in San Juan.After his administrative claim under the Federal Tort Claims Act (FTCA) was denied, the plaintiff filed suit in the United States District Court for the District of Puerto Rico. He initially brought constitutional claims against individual Coast Guard officers and a tort claim against the federal government under the FTCA’s law enforcement proviso, but later voluntarily dismissed the constitutional claims. The government moved to dismiss the FTCA claim, arguing the claim was subject to admiralty law and thus exclusively governed by the Suits in Admiralty Act (SIAA). The magistrate judge recommended dismissal, concluding the FTCA did not apply because the SIAA provided the exclusive remedy. The judge further recommended denying the plaintiff’s request to amend his complaint to add an SIAA claim because it would be time-barred. The district court adopted these recommendations and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the First Circuit affirmed. The court held that the plaintiff’s claim arose under maritime jurisdiction and was therefore governed exclusively by the SIAA, not the FTCA. Because the FTCA expressly excludes claims for which a remedy is provided by the SIAA, the plaintiff could not proceed under the FTCA, even if his SIAA claim was time-barred. The dismissal with prejudice was affirmed. View "Lantigua-Nunez v. US Coast Guard" on Justia Law

A dispute arose between a regional fishermen’s association and the federal government concerning changes to catch limits for several fish species in the Northeast Multispecies Fishery Management Plan. The association, representing commercial fishermen allegedly harmed by reduced catch limits, challenged the legality of the Framework Adjustment 65 Final Rule and its implementing regulations. At the core of the association’s argument was the claim that the involvement of the New England Fishery Management Council in the development of these rules violated the U.S. Constitution’s Appointments Clause. The association argued that the Council exercised significant authority in the regulatory process but its members were not properly appointed as federal officers.The United States District Court for the District of Maine reviewed the case. It concluded that the association had standing due to the economic injury suffered by its members. The district court rejected the primary constitutional claim, holding that the Council’s role was advisory and final binding authority rested solely with the Secretary of Commerce, who promulgated the regulations. The court did, however, agree with the association in part, finding certain unrelated statutory provisions unconstitutional, but determined that this did not entitle the association to its requested relief. The district court severed those statutory provisions.The United States Court of Appeals for the First Circuit heard the appeal. After reviewing the statutory framework and the specific facts, the court held that the Council’s role was advisory and did not amount to the exercise of significant federal authority under the Appointments Clause. The harm to the association’s members derived from the Secretary’s independent decision to promulgate the binding regulations, not from the Council’s recommendations. The First Circuit affirmed the denial of injunctive and declaratory relief and reversed the district court’s severance of the unrelated statutory provisions. View "New England Fishermen's Stewardship Association v. Lutnick" on Justia Law

A volunteer firefighter with a fire district in New York suffered a serious foot injury while aboard the district’s firefighting vessel responding to a reported boat fire on the Hudson River. He was injured when he tried to prevent a collision between his vessel and a police boat. After the accident, he received compensation under New York’s Volunteer Firefighters’ Benefit Law, which provides workers’ compensation-like benefits for volunteers injured in the line of duty. Despite receiving these benefits, he filed claims in federal court against the fire district, alleging negligence and unseaworthiness under federal maritime law.The United States District Court for the Southern District of New York granted summary judgment to the fire district, finding that the firefighter was not entitled to bring claims under the Jones Act or under the Supreme Court’s precedent in Seas Shipping Co. v. Sieracki, and that the exclusive remedy provision of New York’s Volunteer Firefighters’ Benefit Law barred his general maritime law negligence claim. The firefighter appealed, contesting the denial of his Sieracki unseaworthiness and general maritime negligence claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court erred in concluding, as a matter of law, that the firefighter was not entitled to the warranty of seaworthiness extended to so-called "Sieracki seamen." It also concluded that New York’s exclusive remedy provision could not bar his federal negligence claim under general maritime law, given the significant federal interest in uniform maritime remedies. The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings to determine whether the firefighter met the requirements for Sieracki seaman status and to allow his general maritime negligence claim to proceed. View "In re Complaint of Verplanck Fire District" on Justia Law

A shipping dispute arose when a common carrier charged a trucking company detention fees for the late return of shipping equipment. The delay was caused by a COVID-19-related closure at the consignee’s plant, and when the trucking company attempted to return the equipment, the port was closed for three days due to scheduled closures and a holiday. The trucking company disputed a portion of the detention charges, arguing that it was impossible to return the equipment while the port’s gates were closed.The Federal Maritime Commission initially found the disputed charges unreasonable, concluding they could not have incentivized a faster return because the port was not accepting containers during the relevant days. The carrier sought review in the United States Court of Appeals for the District of Columbia Circuit, which vacated and remanded, instructing the Commission to address specific arguments and analyze the charges under the proper legal framework, especially the “incentive principle” as articulated in the Commission’s Interpretive Rule. On remand, the Commission reaffirmed that the charges were unreasonable. It emphasized that the purpose of detention fees is to promote freight fluidity and found that, under the uncontested facts—namely, the plant closure, the port’s closure, and the absence of costs to the carrier—the charges did not serve that purpose. The Commission also addressed and rejected each of the carrier’s justifications and extenuating circumstances.The United States Court of Appeals for the District of Columbia Circuit reviewed the Commission’s order on remand. The court held that the Commission’s determination was reasonable, supported by substantial evidence, and consistent with its Interpretive Rule. The court emphasized that the relevant standard is whether the charges promoted freight fluidity and found that the fees did not do so under the specific facts. The court denied the petition for review. View "Evergreen Shipping Agency (America) Corp. v. FMC" on Justia Law

A hotel guest, who was staying at a lodge as part of a cruise package, fell in his bathroom after tripping over a raised shower ledge situated close to the toilet. He alleged that the bathroom’s configuration was unreasonably dangerous, and that the cruise line and hotel operator were negligent in constructing or maintaining that configuration. The guest asserted both a traditional maritime negligence claim and an alternative theory of negligence per se, arguing that the bathroom violated applicable plumbing codes.The United States District Court for the Central District of California granted summary judgment for the defendants on both theories. Regarding the negligence claim, the district court ruled that the plaintiff had not provided evidence that the defendants had actual or constructive notice of the alleged dangerous condition. On the negligence per se theory, the district court found that there was insufficient evidence that a plumbing code violation caused the plaintiff’s injury.The United States Court of Appeals for the Ninth Circuit reviewed the case. The appellate court held that, because the defendants owned and constructed the lodge’s bathroom, there was no dispute that they knew or should have known the configuration existed. It found that the plaintiff’s expert evidence created a genuine dispute about whether the defendants knew or should have known that the configuration was unreasonably dangerous. Therefore, the Ninth Circuit vacated the district court’s summary judgment on the maritime negligence claim. However, the appellate court agreed with the district court that the defendants were entitled to summary judgment on the negligence per se theory, concluding that a movable shower curtain did not violate the cited plumbing code. The Ninth Circuit affirmed summary judgment for the defendants on negligence per se and remanded the general negligence claim for further proceedings. View "PETREY V. PRINCESS CRUISE LINES, LTD." on Justia Law

A seaman who worked aboard a Cayman Islands-flagged yacht suffered a right shoulder injury while helping recover an underwater scooter at the direction of his captain. After the incident, the seaman alleged he was denied pain medication, reassigned to night shifts to hide his injury from guests, and eventually repatriated to his home country without his belongings. He sued the yacht’s beneficial owner, the captain, the vessel’s record owner, his nominal employer, the yacht’s manager, and the insurer, asserting various claims including negligence under the Jones Act, unseaworthiness, failure to provide maintenance and cure, failure to treat, negligence, conversion, and breach of insurance contract.The defendants (except the insurer) removed the case to the United States District Court for the Southern District of Florida under the New York Convention, citing an arbitration provision in the seaman’s employment agreement requiring disputes to be arbitrated in the Cayman Islands. The district court compelled arbitration as to the Jones Act, maintenance and cure, and failure to treat claims against the yacht owner, the beneficial owner, and the employer, but remanded the remaining claims to state court. The insurer later settled.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision compelling arbitration for the Jones Act, maintenance and cure, and failure to treat claims against the nominal employer, and for the maintenance and cure and failure to treat claims against the yacht owner and beneficial owner. However, it reversed the order to the extent it compelled arbitration of the Jones Act claim against the yacht owner and beneficial owner, finding insufficient allegations of concerted misconduct to warrant estoppel. The court dismissed the cross-appeal for lack of jurisdiction as to the remanded claims. The main holding is that arbitration must be compelled for the relevant claims as to the nominal employer, and for maintenance and cure and failure to treat as to the yacht owner and beneficial owner, but not for the Jones Act claim against the latter two. View "Chemaly v. Lampert" on Justia Law