Justia Admiralty & Maritime Law Opinion Summaries

An international commodity trading company supplied marine fuel oil to a cargo vessel that was time chartered to a German company. Because the charterer had poor credit, a UAE-based sister company guaranteed its obligations under the charter. In October 2022, an employee of the guarantor sought fuel through a broker, which then contacted the trading company to arrange delivery. The broker communicated the quote and order details, and the fuel was delivered to the vessel in Spain. The trading company issued an invoice to the guarantor, but no payment was made by any party involved. The contract for the sale included a choice-of-law provision referencing United States law and incorporated general terms and conditions by reference.The United States District Court for the Eastern District of Louisiana reviewed the case after the vessel was arrested in New Orleans and the owner posted bond. The parties filed cross-motions for summary judgment, both of which were denied due to factual disputes. Following a bench trial, the district court found that the choice-of-law provision was effectively incorporated, and that the trading company was entitled to a maritime lien under American law. The court determined that the guarantor had apparent authority to bind the charterer in procuring the fuel, which in turn could bind the vessel. The district court awarded the trading company the amount invoiced, prejudgment interest, and custodia legis expenses.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that United States law governed the dispute due to valid incorporation of the choice-of-law provision and that the trading company was entitled to a maritime lien under the Commercial Instruments and Maritime Liens Act. The court found that the guarantor had apparent authority to act for the charterer and that the price charged for the fuel was reasonable under industry standards. View "Three Fifty Markets v. Argos M M/V" on Justia Law

A fire broke out on the passenger dive boat M.V. Conception during a scuba diving excursion in September 2019, resulting in the deaths of thirty-four people who were trapped below deck. The Coast Guard had inspected the vessel multiple times before the incident and had found it fit for service, not identifying any safety hazards related to electrical wiring, plastic trash cans, or plastic chairs. Personal representatives of the deceased and one injured survivor filed suit against the United States, alleging that the Coast Guard’s negligent inspection and failure to identify these hazards caused the tragedy.The United States District Court for the Central District of California was the first to review the case. The government moved to dismiss the action for lack of subject matter jurisdiction, arguing that the discretionary function exception to the Suits in Admiralty Act (SIAA) applied. The district court agreed, finding that the relevant statutes and regulations gave Coast Guard inspectors discretion in how to conduct vessel inspections and in determining what constituted hazardous conditions. As a result, plaintiffs’ claims were barred by the discretionary function exception, and the suit was dismissed.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that its prior precedent, Earles v. United States, which applies the discretionary function exception from the Federal Tort Claims Act (FTCA) to the SIAA, remained binding and had not been overruled by the Supreme Court’s decision in Thacker v. Tennessee Valley Authority. The court further found that no specific statute, regulation, or policy required the Coast Guard to identify the hazards alleged by plaintiffs, and that the inspection process involved discretionary, policy-based decisions. Accordingly, the discretionary function exception barred the suit, and dismissal for lack of subject matter jurisdiction was proper. View "Fiedler v. United States" on Justia Law

Genesis Marine, LLC owned and operated the towing vessel M/V Anaconda and two barges, collectively valued at $12.5 million. Brandon Darrow, a tankerman employed by Genesis, suffered a severe back injury on December 23, 2020 while working aboard the vessel. Following the injury, Darrow underwent multiple surgeries and was ultimately deemed permanently disabled and unable to return to work. His medical records and expert evaluations indicated extensive pain, ongoing disability, and significant future care needs. Darrow’s counsel sent Genesis periodic updates regarding his medical condition and proposed damages, including an eventual settlement demand exceeding $20 million.Darrow filed a tort lawsuit against Genesis in Louisiana state court in December 2021, alleging negligence and unseaworthiness and seeking various categories of damages. Genesis filed an answer in August 2022, which included an affirmative defense invoking limitation of liability under federal law. Discovery continued, during which Genesis received detailed documentation of Darrow’s injuries, treatments, and expert reports estimating damages in excess of the vessel’s value. In August 2024, Darrow’s experts further confirmed his total and permanent disability and submitted updated damage estimates.On December 13, 2024, Genesis initiated a limitation of liability action in the United States District Court for the Eastern District of Louisiana, arguing it was timely because it was filed within six months of Darrow’s August 2024 settlement demand. Darrow moved for summary judgment, asserting the limitation action was untimely under 46 U.S.C. § 30529(a) because Genesis had received written notice of a reasonable possibility that damages would exceed the vessel’s value well before June 2024. The district court granted summary judgment for Darrow, and Genesis appealed.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment, holding that Genesis’s limitation action was untimely because Genesis had received sufficient written notice of a reasonable possibility that the claim would exceed the vessel’s value more than six months before filing the limitation action. View "Genesis Marine v. Darrow" on Justia Law

In November 2020, a United States Coast Guard cutter intercepted a vessel in international waters, far from Colombia. The vessel attempted to flee but was stopped and boarded. On board, authorities found three occupants—two Costa Rican nationals, including Munoz, and a Colombian national—and seized 383 kilograms of cocaine. The vessel lacked any registration documents, flag, or markings indicating nationality, and all occupants claimed to be the master without asserting the vessel’s nationality when prompted by Coast Guard officials. Based on these facts, the Coast Guard determined the vessel was subject to United States jurisdiction.A grand jury in the District Court of the Virgin Islands indicted Munoz for conspiracy and possession with intent to distribute cocaine under the Maritime Drug Law Enforcement Act (MDLEA). Munoz moved to dismiss the indictment, arguing that the MDLEA was unconstitutional and that the United States lacked jurisdiction over the vessel, requesting an evidentiary hearing. The District Court denied his motion without a hearing. Munoz then entered a conditional guilty plea to the conspiracy charge, preserving his right to appeal the denial of his motion to dismiss. After sentencing, the government dismissed the possession charge per the plea agreement, and Munoz timely appealed.The United States Court of Appeals for the Third Circuit reviewed Munoz’s constitutional challenge to the MDLEA and the District Court’s refusal to hold an evidentiary hearing. The court held that the MDLEA does not exceed Congress’s authority under the Felonies Clause of Article I, Section 8, Clause 10 of the Constitution, because the Felonies Clause is not limited by international law. It also held that the District Court did not abuse its discretion by declining to hold an evidentiary hearing, as the parties had stipulated to all material facts, leaving only legal questions for resolution. The Third Circuit affirmed the judgment. View "USA v. Munoz" on Justia Law

A Singapore-based company that supplies offshore vessels entered into a charter agreement with a Mexico-based marine oil and gas company. The agreement allowed the Mexican company to charter a vessel for eighteen months, with provisions for termination if payments were not made and an obligation to redeliver the vessel at the end of the term. After the charter expired, the Singaporean company alleged that the Mexican company failed to pay required fees and did not return the vessel, leading to arbitration in Singapore. The arbitrator awarded the Singaporean company damages and ordered the vessel’s return, but the Mexican company did not comply. Meanwhile, an email revealed that the Mexican company was set to receive a large refund from a third party, to be sent to a U.S. bank account in the name of a related U.S. entity.The Singaporean company filed suit in the United States District Court for the Southern District of Texas, seeking to attach the funds in the U.S. account as security for the arbitration award under federal maritime law and, later, Texas state law. The district court initially granted the writ of garnishment, but after limited discovery, vacated the writ, finding no evidence that the Mexican company owned the funds in the U.S. account. The district court also denied the plaintiff’s request for leave to amend its complaint to assert an alter ego theory, which would have permitted attachment based on state law.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court abused its discretion by failing to consider relevant evidence and legal standards regarding ownership and control of the funds. The appellate court also determined that the district court erred in denying leave to amend without adequate explanation. The Fifth Circuit vacated the district court’s order and remanded the case, instructing the district court to allow the plaintiff to amend its complaint. View "CH Offshore v. Mexiship Ocean" on Justia Law

Alberto Alvarado was employed through a temporary staffing agency and assigned to Jacintoport International, L.L.C. (JPI) for work as a longshoreman at the Port of Houston. On December 12, 2020, while descending a ladder into the cargo hold of the BBC Sapphire, a ship owned and operated by Briese Schiffahrts entities, Alvarado slipped due to poor lighting and condensation, falling about fifteen feet and sustaining serious injuries. Alvarado asserted that neither the ship’s crew nor JPI provided adequate warnings or instructions regarding the ladder’s condition and configuration.After the accident, Alvarado filed suit in state court against the BBC Sapphire’s owner/operator and JPI, alleging negligence and gross negligence under the Longshore and Harbor Workers’ Compensation Act (LHWCA). The defendants removed the case to the United States District Court for the Southern District of Texas. The BBC Sapphire moved for summary judgment, arguing there was no evidence of a breached duty under the LHWCA, while JPI argued that as Alvarado’s borrowing employer, its provision of workers’ compensation barred his negligence claim. The district court granted both motions for summary judgment.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The appellate court held that Alvarado failed to raise genuine disputes of material fact regarding the shipowner’s breach of the LHWCA’s turnover or active-control duties, as the hazards were either open and obvious or not under the shipowner’s active control at the relevant time. The court also concluded that JPI was Alvarado’s borrowing employer as a matter of law and, having secured workers’ compensation coverage for him, was shielded from negligence liability by the LHWCA’s exclusive-remedy provision. The Fifth Circuit affirmed the district court’s summary judgment in favor of both defendants. View "Alvarado v. Briese Schiffahrts" on Justia Law

A group of Maine lobstermen challenged a state rule requiring all federally permitted lobster fishers to install electronic tracking devices on their vessels, which transmit GPS location data whenever the vessels are in the water. This rule was adopted by the Maine Department of Marine Resources (MDMR) to comply with an addendum to the Atlantic States Marine Fisheries Commission’s American Lobster Fishery Management Plan. The addendum aimed to reduce risks to North Atlantic right whales, improve fishery data, and support regulatory enforcement. The tracking devices must remain powered and transmit data at all times, including when vessels are docked or used for personal purposes.The plaintiffs filed suit in the United States District Court for the District of Maine, arguing that the MDMR Rule violated their rights under the Fourth Amendment, as well as equal protection and state administrative law. The district court granted the state’s motion to dismiss, holding that the plaintiffs failed to state a claim under the Fourth Amendment because the lobster fishery is a closely regulated industry and the rule was not unreasonably invasive. The court noted several concessions by the parties, including that the GPS tracking constituted a search, that the lobster industry is closely regulated, and that the search was administrative in nature.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that the lobster industry is a closely regulated industry and that the administrative search exception, as articulated in New York v. Burger, 482 U.S. 691 (1987), applied. The court found that the MDMR Rule satisfied the Burger test: it served a substantial government interest, warrantless searches were necessary to the regulatory scheme, and the rule provided a constitutionally adequate substitute for a warrant. The First Circuit affirmed the district court’s dismissal. View "Thompson v. Wilson" on Justia Law

A company operating stevedoring services at the Port of Mobile, Alabama, entered into a collective bargaining agreement with a union representing longshore workers. The agreement included a no-strike provision and outlined procedures for resolving disputes, including arbitration. After an alleged strike by union members, the company filed a lawsuit in state court seeking a temporary restraining order and later damages for breach of the no-strike provision. The state court issued a restraining order, ending the strike within days. The union subsequently removed the case to federal court, where the company amended its complaint to seek damages, asserting that all conditions precedent for judicial action had been met.In the United States District Court for the Southern District of Alabama, the union moved to compel arbitration, arguing that the dispute should be resolved through the arbitration process outlined in the collective bargaining agreement. The district court denied the motion, concluding that the agreement permitted the company to seek monetary damages in court for violations of the no-strike provision. The union then filed an interlocutory appeal of the order denying arbitration, while the underlying damages action remained pending.The United States Court of Appeals for the Eleventh Circuit reviewed whether it had jurisdiction to hear the interlocutory appeal. The court held that it lacked appellate jurisdiction because the Federal Arbitration Act’s provision for interlocutory appeals does not apply to collective bargaining agreements covering workers engaged in interstate commerce, such as longshoremen. The court also found no basis for jurisdiction under the Labor Management Relations Act or the collateral-order doctrine. Accordingly, the Eleventh Circuit dismissed the appeal for lack of jurisdiction, leaving the district court’s order in place and expressing no opinion on the merits of the underlying dispute. View "APM Terminals Mobile, LLC v. International Longshoremen's Association" on Justia Law

A welder was injured while working on a launch site on the Mississippi River, operated by two closely related companies. The injury occurred when a defective hook, lacking a required safety latch, struck him during a crane operation, causing him to fall and sustain multiple injuries, including a fractured eye socket and a cervical disk injury. Over the following months, he underwent surgery and was prescribed pain medications. After his prescriptions ran out, he attempted to manage his pain with over-the-counter drugs, but ultimately died from an overdose of street fentanyl mixed with Xylazine, a non-prescribed animal tranquilizer.The estate of the deceased sued the two companies for personal injury under the Jones Act, general maritime law, and the Longshore and Harbor Workers’ Compensation Act (LHWCA) in the United States District Court for the Eastern District of Louisiana. After a bench trial, the district court found the companies liable for vessel negligence under the LHWCA, determining that the defective hook was an appurtenance of the vessel and the proximate cause of the initial injury. The court also found the two companies to be essentially the same entity and awarded damages to the decedent’s children and mother, including for wrongful death and loss of consortium.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s findings for clear error and legal conclusions de novo. The Fifth Circuit held that while the defective hook was the proximate cause of the workplace injury, the ingestion of illegal drugs was a superseding cause of death, breaking the chain of causation from the workplace injury. The court reversed the award of damages stemming from the death and loss of consortium, concluding that the companies were not liable for the decedent’s death, and remanded for further proceedings. View "Bommarito v. Belle Chasse Marine Trans" on Justia Law

Nearly a million barrels of crude oil owned by a U.S. company were seized from a vessel in Venezuelan waters by Venezuelan authorities under threat of force. The oil was insured under a marine cargo reinsurance policy that covered losses arising from war-related risks, including “insurrection.” The insured company claimed that the political turmoil in Venezuela, including the contested presidency and violent suppression of opposition, constituted an insurrection as defined by the policy. The reinsurers denied coverage, arguing that the events did not meet the policy’s definition of insurrection, leading to litigation.The United States District Court for the Southern District of New York reviewed cross-motions for summary judgment. The court found the term “insurrection” in the policy to be ambiguous and, applying New York law and the doctrine of contra proferentem, construed the ambiguity in favor of the insured. The court held that the Maduro regime’s actions constituted an insurrection within the meaning of the policy. The case proceeded to trial on causation and damages, where the jury found in favor of the insured on most issues, awarding over $54 million in damages plus interest.On appeal, the United States Court of Appeals for the Second Circuit considered challenges to the district court’s summary judgment ruling, judicial notice orders, and jury instructions on causation. The Second Circuit held that the district court did not err or abuse its discretion in any of the challenged rulings. It affirmed that the policy’s “arising from” language required only but-for causation, not proximate causation. The court affirmed the district court’s judgment in all respects, upholding the award to the insured. View "CITGO Petroleum Corp. v. Ascot Underwriting Ltd." on Justia Law