Justia Admiralty & Maritime Law Opinion Summaries

Marek Matthews, a seaman and captain, filed a lawsuit against Tidewater, Inc. and Tidewater Crewing, Ltd., alleging that he was exposed to toxic chemicals during his employment, resulting in severe health issues including end-stage renal failure and stage IV cancer. Matthews, a Florida resident, claimed that the exposure occurred while working on offshore supply vessels in the Red Sea. His employment contract included a forum-selection clause mandating that any disputes be litigated in the High Court of Justice in London, England.Initially, Matthews and other plaintiffs filed the suit in Louisiana state court, asserting claims under the Jones Act and general maritime law. Tidewater removed the case to the United States District Court for the Eastern District of Louisiana and moved to dismiss it based on the forum-selection clause and, alternatively, for failure to state a claim. The district court granted the motion to dismiss on forum non conveniens grounds, finding the forum-selection clause valid and enforceable. Matthews's subsequent motion to reconsider the dismissal was denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision, holding that the forum-selection clause was enforceable. The court applied a de novo review to the enforceability of the clause and an abuse of discretion standard to the forum non conveniens analysis. It concluded that Matthews did not meet the heavy burden of proving the clause was unreasonable under the circumstances, despite his health conditions and Louisiana's public policy against such clauses. The court emphasized the federal policy favoring the enforcement of forum-selection clauses in maritime contracts, which outweighed the conflicting state policy. View "Matthews v. Tidewater" on Justia Law

Three foreign nationals, crewmembers aboard the vessel MARGUERITA, were detained in the United States after the vessel was held in port in Maine due to alleged improper disposal of bilge water and inaccurate record-keeping. The plaintiffs were ordered to remain in the U.S. as potential material witnesses. They were later allowed to leave but returned for trial and were awarded for their contributions to the conviction of the vessel's operator.The plaintiffs filed a lawsuit under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics and the Federal Tort Claims Act (FTCA) against various U.S. government entities and officials, alleging violations of their constitutional rights and various tort claims. The U.S. District Court for the District of Maine dismissed the Bivens claim and granted summary judgment for the defendants on the FTCA claims. The court found that the plaintiffs' detention and the revocation of their landing permits were authorized and that the plaintiffs did not show that the actions taken by the government officials were unlawful or unreasonable.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the requirement for ships to maintain an Oil Record Book under 33 C.F.R. § 151.25 is valid and that the plaintiffs' detention was justified under the circumstances. The court also found that the plaintiffs failed to establish their claims for false arrest, false imprisonment, abuse of process, and intentional infliction of emotional distress under the FTCA. Additionally, the court concluded that the Bivens claim presented a new context and that special factors counseled hesitation in extending a Bivens remedy, particularly given the availability of alternative remedies and the implications for government policy and international relations. View "Hornof v. United States" on Justia Law

In 2019, a 13,000-volt electric cable owned by Baltimore Gas & Electric Co. (BG&E) was damaged at the bottom of Eli Cove in Pasadena, Maryland. BG&E alleged that the cable was struck by a barge owned by Coastline Commercial Contracting while performing work for a couple who owned property on the cove. BG&E sued Coastline and the property owners for negligence, invoking federal admiralty jurisdiction over the claim against Coastline and supplemental jurisdiction over the claim against the property owners. The central issue was whether a U.S. court has admiralty jurisdiction to determine the existence and extent of Coastline’s tort liability.The United States District Court for the District of Maryland dismissed the case, ruling that it did not have admiralty jurisdiction. The court found that Eli Cove was not part of the navigable waters because it could not accommodate commercial navigation and was not susceptible of being used as a highway for commerce. The court also found that the incident did not bear a significant relationship to traditional maritime activity because Coastline’s barge was present on Eli Cove solely to extend an existing pier at a private residence.The United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court held that the case falls within federal admiralty jurisdiction. The court found that the district court applied the incorrect standard when determining whether Eli Cove was navigable and whether the incident bore a significant relationship to traditional maritime activity. The court held that the incident had a potentially disruptive impact on maritime commerce and that the activity giving rise to the incident bore a substantial relationship to traditional maritime activity. The case was remanded for further proceedings. View "Baltimore Gas and Electric Company v. Coastline Commercial Contracting, Inc." on Justia Law

The case revolves around Evergreen Shipping Agency (America) Corp. and its affiliates, who were charged by the Federal Maritime Commission (FMC) for imposing "unjust and unreasonable" detention charges on TCW, Inc., a trucking company. The charges were for the late return of a shipping container. The FMC argued that the charges were unreasonable as they were levied for days when the port was closed and could not have accepted a returned container. Evergreen contested this decision, arguing that the FMC's application of the interpretive rule was arbitrary and capricious, in violation of the Administrative Procedure Act.The FMC had previously ruled in favor of TCW, Inc. in a small claims program. The Commission then reviewed the decision, focusing on the application of the interpretive rule on demurrage and detention. The FMC upheld the initial decision, stating that no amount of detention can incentivize the return of a container when the terminal cannot accept the container. The Commission dismissed Evergreen's arguments that failing to impose detention charges during the port closure would have disincentivized the return of the container before the closure.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and found the FMC's decision to be arbitrary and capricious. The court noted that the FMC failed to consider relevant factors and did not provide a reasoned explanation for several aspects of its decision. The court also found that the FMC's application of the incentive principle was illogical. The court concluded that a detention charge does not necessarily lack any incentivizing effect because it is levied for a day on which a container cannot be returned to a marine terminal. The court granted the petition for review, vacated the Commission’s order, and remanded the matter to the agency for further proceedings. View "Evergreen Shipping Agency (America) Corp. v. Federal Maritime Commission" on Justia Law

The case revolves around Wapiti Energy, L.L.C. ("Wapiti"), the owner of a 155-foot tank barge, the SMI 315, which broke free of its moorings and ran aground in marshland owned by a third party during Hurricane Ida. The vessel was insured under a marine package policy issued by Clear Spring Property and Casualty Company ("Clear Spring"). The policy provided coverage for wreck removal expenses that are compulsory by law. After the incident, Wapiti incurred expenses in removing the stranded vessel from the marshland and sought reimbursement from Clear Spring. Clear Spring, however, moved for summary judgment, arguing that the removal of the SMI 315 was not compulsory by law, and thus, it was not obligated to reimburse the expenses.The United States District Court for the Southern District of Texas ruled in favor of Clear Spring, concluding that removal of the SMI 315 was not compulsory by law and dismissing Wapiti’s claims. Wapiti appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the lower court's decision. The court concluded that the removal of the SMI 315 was compelled by the Louisiana possessory action, which made removal compulsory by law. The court reasoned that at the time of the incident, a reasonable owner would know that the barge stranded on a third party's property would expose them to a high probability of having to comply with an injunction mandating the removal of the vessel. Therefore, Wapiti's proactive removal of the vessel from the third party's marshland was warranted, and Clear Spring was obligated to reimburse the expenses. The case was remanded for further proceedings consistent with this opinion. View "Wapiti Energy v. Clear Spring Property and Casualty Co." on Justia Law

In March 2020, seven crewmembers of the M/V Greg Mortimer cruise ship filed a lawsuit against several companies, including CMI Leisure Management, Inc., Cruise Management International, Inc., and Vikand Medical Solutions, LLC. The crewmembers alleged that the decision to sail during the COVID-19 pandemic exposed them to foreseeable harms, resulting in six of them contracting the virus. The crewmembers had signed employment agreements with other companies that contained forum-selection and choice-of-law clauses requiring disputes to be brought in the Bahamas under Bahamian law.The United States District Court for the Southern District of Florida dismissed the action based on the forum-selection clause. The court ruled that the defendants, who were not parties to the employment agreements, could invoke the forum-selection clause under the doctrine of equitable estoppel.Upon review, the United States Court of Appeals for the Eleventh Circuit vacated and remanded the decision. The appellate court held that the defendants could not invoke the forum-selection clause in the employment agreements under the doctrine of equitable estoppel. The court reasoned that the crewmembers' claims did not rely on the terms of their employment agreements, and thus, equitable estoppel did not apply. The court remanded the case for further proceedings consistent with its opinion. View "Usme v. CMI Leisure Management, Inc." on Justia Law

The Supreme Court of the United States reviewed two cases involving challenges to a rule promulgated by the National Marine Fisheries Service under the Magnuson-Stevens Act. The rule required certain fishing vessels to carry observers onboard to collect data necessary for fishery conservation and management, with the cost of these observers to be borne by the vessel owners. The petitioners, various fishing businesses, argued that the Act did not authorize the Fisheries Service to impose these costs on them.In the lower courts, the District Court for the District of Columbia Circuit and the First Circuit Court of Appeals both upheld the rule. They applied the Chevron framework, a two-step process used to interpret statutes administered by federal agencies. Under this framework, if a statute is ambiguous, courts defer to the agency's interpretation as long as it is reasonable. Both courts found that the Magnuson-Stevens Act was ambiguous on the issue of observer costs and deferred to the Fisheries Service's interpretation.The Supreme Court, however, overruled the Chevron doctrine, holding that it was inconsistent with the Administrative Procedure Act (APA). The APA requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority. Courts may not defer to an agency interpretation of the law simply because a statute is ambiguous. The Court vacated the judgments of the lower courts and remanded the cases for further proceedings consistent with this opinion. The Court emphasized that while courts may seek guidance from the interpretations of those responsible for implementing particular statutes, they must not defer to these interpretations. Instead, they must independently interpret the statute and ensure that the agency has acted within its statutory authority. View "Loper Bright Enterprises v. Raimondo" on Justia Law

Brent Adkins, a crew member on one of Marathon Petroleum Company’s inland river barges, claimed that his service on the barge caused his lung function to deteriorate. He brought claims against Marathon under the Jones Act and general maritime law. Adkins worked on the barge from 2008 to 2012. During this time, he underwent several medical examinations which showed a decline in his Forced Vital Capacity (FVC), a measure of lung function. Despite this, Marathon cleared Adkins to work without restriction. In March 2012, Adkins fell ill and was diagnosed with an irregular heartbeat and heat intolerance. He never returned to work for Marathon and subsequently sued the company.The case was initially filed in Louisiana state court but was dismissed on forum non conveniens grounds. Adkins then sued Marathon in the Southern District of Ohio. He claimed that repeated exposure to hydrogen sulfide and other hydrocarbon fumes while working on the barge caused his pulmonary function to deteriorate. He also claimed that Marathon failed to pay maintenance and cure for the injuries and illnesses he sustained while working on the barge. Marathon moved for summary judgment on all of Adkins’s claims. The district court granted Marathon’s motion for summary judgment and denied Adkins’s.The United States Court of Appeals for the Sixth Circuit affirmed in part, reversed in part, and remanded to the district court. The court held that Adkins needed expert medical proof to show causation on his Jones Act negligence claims. However, the court reversed the district court’s grant of summary judgment to Marathon on Adkins’s maintenance-and-cure claim, finding that Adkins presented evidence that created a genuine dispute of material fact about whether his lung problems manifested while he was in Marathon’s service. The case was remanded for further proceedings. View "Adkins v. Marathon Petroleum Co., LP" on Justia Law

The plaintiff, Mary Rodgers-Rouzier, worked as a bartender on steamboats operated by American Queen. She alleged that she and her coworkers were wrongly denied overtime wages. Rodgers-Rouzier filed a suit as a collective action, and over one hundred of her coworkers joined her proposed collective action. Meanwhile, American Queen moved to dismiss the case, arguing that Rodgers-Rouzier had agreed to arbitration. The district court denied the motion, but American Queen moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections.The district court had previously denied American Queen's motion to dismiss the case for improper venue because Rodgers-Rouzier had agreed to arbitration. However, American Queen then moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections that American Queen had waived its argument and the court lacked authority to apply Indiana law in this context. The court further determined that all the workers who had filed consent forms were not parties to the action.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The court concluded that although American Queen’s arguments were not waived and the court had authority to enforce the arbitration agreement under Indiana law, Indiana law would hold American Queen to its bargain that its arbitration agreement was governed by the Federal Arbitration Act (FAA). Therefore, Rodgers-Rouzier’s case may continue in federal court. The court did not decide whether it may do so as a collective action and left that question for further litigation. View "Rodgers-Rouzier v. American Queen Steamboat Operating Company, LLC" on Justia Law

The United States Coast Guard seized a vessel in the Dominican Republic's Exclusive Economic Zone (EEZ) that bore no nationality indicators. The crew claimed Colombian nationality for the vessel, but Colombia could not confirm or deny the vessel's registry, rendering it stateless under the Maritime Drug Law Enforcement Act (MDLEA). The vessel was found to contain drugs, leading to the arrest and prosecution of the crew members, Jhonathan Alfonso, Jose Jorge Kohen, and Jose Miguel Rosario-Rojas, under the MDLEA.The defendants moved to dismiss the indictment, arguing that the MDLEA was unconstitutional as applied to them because they were arrested in the EEZ, which they asserted is not part of the "high seas" as defined by customary international law. The district court denied the motion, concluding that it had subject matter jurisdiction under the MDLEA. The defendants subsequently pleaded guilty to conspiracy to possess with intent to distribute a controlled substance while on board a vessel subject to the jurisdiction of the United States.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court concluded that the EEZ is part of the "high seas" and thus within Congress’s authority under the Felonies Clause. The court also concluded that the defendants could not show any plain error with regard to the MDLEA’s definition of a vessel without nationality as including vessels where registry is asserted but cannot be confirmed or denied by the foreign country. View "United States v. Alfonso" on Justia Law