Keith Bray, et al v. The Unidentified, Shipwrecked

Appellant, a researcher of sunken sea vessels, appealed the dismissal of his contract rescission claim against appellee, a Nevada Corporation engaged in deep sea exploration and recovery, where appellant alleged that appellee fraudulently induced him into entering a contract to provide research and data concerning the location of a long-sunk and potentially highly valuable Spanish cargo vessel. At issue was whether appellant set out a claim cognizable in admiralty jurisdiction where the "nature and character of the contract...has reference to maritime service or maritime transactions." The court held that appellant's claim was cognizable in federal admiralty jurisdiction where contracts to provide research to assist in locating and recovering a sunken vessel were considered maritime in nature.