Justia Admiralty & Maritime Law Opinion Summaries
Prickett v. Bonnier Corp.
This case arose from a movie-making accident. After her father was injured diving in French Polynesia, Mira Chloe Prickett sued Bonnier Corporation and World Publications, LLC (collectively Bonnier) for compensatory and punitive damages under general maritime law. The trial court granted a judgment on the pleadings against her on the grounds that neither compensatory damages for loss of her father’s society nor punitive damages were available under general maritime law. Appellant Prickett did not cite on appeal any admiralty authority that would allow a child to recover loss of society damages for a nonfatal injury to a non-seaman on the high seas, and – without legislative impetus or compelling logic for such a result – the Court of Appeal declined to do so. The trial court's judgment was affirmed. View "Prickett v. Bonnier Corp." on Justia Law
Panjiva, Inc. v. United States Customs and Border Protection
Plaintiff filed suit alleging that Section 431 of the Smoot-Hawley Tariff Act of 1930, which requires all vessels arriving in the United States to maintain a manifest on which is recorded information about the just-completed voyage and an account of what is on board, requires aircraft entering the United States to make available for public disclosure such manifests detailing the journey and cargo aboard.The Second Circuit affirmed the district court's dismissal in part of plaintiffs' complaint. The court considered the different tools of statutory interpretation and held that section 431(c)(1) continues to require the government to make available for public disclosure manifests only of vessels, meaning "water craft or other contrivance used, or capable of being used, as a means of transportation in water, but...not...aircraft." The court considered plaintiffs' remaining arguments on appeal and concluded that they are without merit. View "Panjiva, Inc. v. United States Customs and Border Protection" on Justia Law
Deloach Marine Services LLC v. Marquette Transportation Co., LLC
After two barge towboats collided on the Mississippi River, the district court found the captains of both vessels negligent to varying degrees. The Fifth Circuit affirmed the district court's apportionment of fault, rejecting Marquette's argument that the district court misinterpreted Inland Navigational Rule 14(d) when it held that the VANPORT was under no duty to propose the manner of passage. Because Marquette's arguments regarding Rules 5 through 8 flow from the district court's putative misreading of Rule 14(d), the court rejected these arguments too. Furthermore, the district court's holdings regarding Rules 5 through 8 were made alternatively to its determinations on ordinary negligence. The court further held that the district court did not err in assigning the VANPORT 30 percent of the liability for the collision. Finally, the court remanded to the district court to consider whether prejudgment interest is proper and, if so, in what amount. View "Deloach Marine Services LLC v. Marquette Transportation Co., LLC" on Justia Law
United States v. Alarcon Sanchez
The Second Circuit affirmed defendant's convictions, after pleading guilty, of conspiring to engage in drug trafficking activity in violation of the Maritime Drug Law Enforcement Act (MDLEA). Defendants challenged the adequacy of their unconditional guilty pleas.The court held that the government has met its evidentiary burden in establishing that defendants' boat was a stateless vessel and thus subject to the jurisdiction of the United States; Section 70506(b) of the MDLEA encompasses land-based conspiratorial conduct, which Congress is authorized to proscribe under the Necessary and Proper Clause; although due process requires a sufficient nexus with the United States for those not on board a stateless vessel to be prosecuted under the MDLEA, in this instance, defendants' prosecutions satisfy due process; and Congress did not exceed its legislative authority in enacting the MDLEA pursuant to the Define and Punish Clause. View "United States v. Alarcon Sanchez" on Justia Law
United States v. Davila-Mendoza
Defendants, three foreign nationals in a foreign vessel in the territorial waters of Jamaica, were arrested by the United States Coast Guard with the consent of the foreign country and prosecuted in the United States for drug-trafficking crimes under the Maritime Drug Law Enforcement Act (MDLEA). Defendants pleaded guilty and preserved their right to appeal the denial of their motion to suppress.The Eleventh Circuit vacated defendant's convictions, holding that the MDLEA is unconstitutional and exceeded Congress's authority under the Foreign Commerce Clause. The court also held that, as applied to defendants, the MDLEA was not a valid exercise of Congress's authority under the Necessary and Proper Clause to effectuate the subsequently enacted 1989 Convention Against Illicit Traffic Treaty and the 1997 Jamaica Bilateral Agreement between the United States and Jamaica. View "United States v. Davila-Mendoza" on Justia Law
Sanchez v. Smart Fabricators of Texas, LLC
After plaintiff was injured when he tripped on a pipe welded to the deck of a jacked-up offshore drilling rig, he filed a negligence action against Smart Fabricators under the Jones Act. The district court denied plaintiff's motion to remand to state court, granting Smart Fabricator's motion for summary judgment. The district court's ruling was based on its conclusion that plaintiff did not qualify as a seaman under the Jones Act.The Fifth Circuit reversed and held that plaintiff qualifies as a seaman under the Jones Act where plaintiff has shown that he had a substantial connection both in nature and duration to the vessels on which he worked. The court agreed with the district court that plaintiff satisfied the duration requirement of the Chandris test because he spent over 70 percent of his employment with SmartFab aboard a rig adjacent to an inland pier and around 19 percent of his employment aboard a rig on the Outer Continental Shelf. The court also held that plaintiff's connection to the vessel was substantial in nature and he satisfied the nature requirement of the Chandris test where plaintiff's work on vessels exposed him to the perils of the sea. The court explained that, although plaintiff was a land-based welder who went home every evening, such work aboard vessels did not disqualify him as a Jones Act seaman. The court remanded with instructions to remand the matter to state court. View "Sanchez v. Smart Fabricators of Texas, LLC" on Justia Law
Higgs v. Costa Crociere S.P.A. Co.
After plaintiff tripped over a bucket in a dining area of a cruise ship and sustained serious injuries, she filed suit against the cruise company, Costa Crociere, for negligently placing the bucket behind a corner in a highly-trafficked area. The jury returned a verdict in her favor for over $1 million. Both parties subsequently appealed. The Eleventh Circuit found Costa's arguments unpersuasive and affirmed the verdict in plaintiff's favor.However, the court held that the appropriate measure of medical damages in a maritime tort case is that reasonable value determined by the jury upon consideration of any relevant evidence, including the amount billed, the amount paid, and any expert testimony and other relevant evidence the parties may offer. In this case, the district court improperly reduced plaintiff's damages by applying a bright-line rule that would categorically limit medical damages to the amount actually paid by an insurer. Therefore, the court vacated the district court's reduction of the medical damages award and remanded for entry of judgment in the amount the jury found to be reasonable. View "Higgs v. Costa Crociere S.P.A. Co." on Justia Law
Mays v. Chevron Pipe Line Co.
After James Mays was killed in an explosion on an offshore platform owned by Chevron, Mays' widow and children filed suit against Chevron for state law wrongful death. Mays was directly employed by Furmanite, a Chevron subcontractor, which serviced valves on Chevron's platforms. At issue was whether Mays' accident was covered by the federal Longshore and Harbor Workers' Compensation Act (LHWCA). The jury found that Mays' death was caused by Chevron's Outer Continental Shelf (OCS) activities, and thus the LHWCA applied and Chevron did not enjoy state immunity.The Fifth Circuit affirmed and rejected Chevron's argument that the district court erred by instructing the jury to consider Chevron's OCS operations in answering the substantial nexus question. The court held that the district court did not misapply Pacific Operators Offshore, LLP v. Valladolid, 565 U.S. 207 (2012), by instructing the jury to determine whether there was a substantial nexus between Mays' death and Chevron's—as opposed to Furmanite's—OCS operations. The court also rejected Chevron's argument that the evidence linking its OCS operations to Mays' death failed to meet the substantial nexus test as a matter of law. Finally, the court held that the district court did not abuse its discretion by refusing to reduce the jury's $2 million loss-of-affection award to Mrs. Mays. View "Mays v. Chevron Pipe Line Co." on Justia Law
Power Authority of the State of New York v. M/V Ellen S. Bouchard
The Authority appealed the district court's grant of summary judgment to defendants, two vessels and their corporate owners, in an action brought under the federal Oil Pollution Act (OPA) and state law. The claims arose from the release of thousands of gallons of oil from a submarine power-transmission cable into Long Island Sound, which the Authority alleges was caused by the defendant vessels dropping anchor.The Second Circuit vacated the district court's order and held that the submarine cable is indeed "used for" one of the enumerated "purposes" in the OPA's definition of "facility." Consequently, the panel found that the cable system is used for at least one of the enumerated purposes in the statute. Therefore, the district court erred in dismissing the Authority's OPA claims and in concluding that the Authority's New York Oil Spill Law claims had to be brought in the parallel proceeding on that basis. The court remanded for further proceedings. View "Power Authority of the State of New York v. M/V Ellen S. Bouchard" on Justia Law
DeRoy v. Carnival Corp.
After injuring her foot on a rug while onboard a Carnival ship, plaintiff filed suit against Carnival in both state and federal court, seeking damages for the injuries she allegedly suffered onboard the ship. In this case, plaintiff entered into a contract with Carnival that contained a forum-selection clause.Under the forum-selection clause's plain language, when jurisdiction for a claim could lie in federal district court, federal court is the only option for a plaintiff. The court held that plaintiff's claim for negligence at sea falls well within the walls of the federal court's admiralty jurisdiction. Even without explicitly invoking admiralty jurisdiction, the court held that plaintiff's complaint is subject to Federal Rule of Civil Procedure 9(h)'s provision rendering her claim an admiralty or maritime claim. View "DeRoy v. Carnival Corp." on Justia Law