Justia Admiralty & Maritime Law Opinion Summaries

A man was injured while working on a man-made island in the Beaufort Sea, which served as an oil and gas drill site. In February, he drove a forklift down a ramp to unload cargo from a sled on the frozen sea. A colleague followed in a wheel loader, lost control, and collided with the sled and the forklift, crushing the man's leg. The man sued the companies owning and operating the island, alleging coverage under the Longshoreman and Harbor Workers’ Compensation Act (LHWCA) and maritime tort jurisdiction.The Superior Court of Alaska dismissed the man's LHWCA claims as unripe and ruled that the accident did not meet the two-prong test for maritime tort jurisdiction. The court found that the accident lacked the potential to disrupt maritime commerce and did not have a substantial relationship to traditional maritime activities. The court also concluded that the Alaska Worker’s Compensation Act (AWCA) barred the man from pursuing state law claims against the companies.The Supreme Court of Alaska reviewed the case. It held that the superior court properly dismissed the LHWCA-related claims, as eligibility for LHWCA benefits does not automatically establish maritime tort jurisdiction, and the LHWCA does not preempt the AWCA. However, the Supreme Court found that the superior court erred in its analysis of the maritime nexus prong. The accident had the potential to disrupt maritime commerce and bore a substantial relationship to traditional maritime activities, such as unloading cargo.The Supreme Court of Alaska reversed the superior court’s dismissal of the maritime tort claims and remanded the case for further proceedings to determine whether the accident met the locus prong of the maritime jurisdiction test. View "Beckwith v. ENI Petroleum US, LLC" on Justia Law

John Bludworth Shipyard, L.L.C. (JBS) performed nearly $3 million in services to combine three vessels into a single dredging unit for a project along the Gulf Coast. The vessels involved were the Captain Frank Bechtolt, the CIT-103, and the Idler Barge. T.W. LaQuay Marine, L.L.C., which owned the Idler Barge and leased the other two vessels, requested the work without the knowledge or consent of the owners, Manson Construction Company and Caillou Island Towing Company, Inc. JBS asserted maritime liens on each vessel for the services provided.The United States District Court for the Southern District of Texas denied JBS’s motion for interlocutory sale of the three-vessel unit and JBS’s motion for summary judgment to confirm the validity of its maritime liens. The court granted Caillou’s motion to vacate the arrest of the CIT-103, finding that JBS did not provide necessaries to the CIT-103 and that there were fact issues regarding the Bechtolt and the Idler Barge. The district court focused on the CIT-103’s old function, disregarding any new function that JBS’s work might have equipped it to perform.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court erred by considering only the CIT-103’s former function and not its new function after the alterations. The appellate court vacated the district court’s grant of Caillou’s motion to vacate the arrest of the CIT-103 and remanded for further proceedings to determine whether JBS’s work constituted necessaries for the CIT-103’s new function. The court dismissed for lack of jurisdiction the remainder of JBS’s appeal challenging the denial of its motions for summary judgment and interlocutory sale. View "Bludworth v. Manson Construction" on Justia Law

Captain Matthew Hight trained with the Saint Lawrence Seaway Pilots Association from 2015 to 2018 to become a maritime pilot on Lake Ontario and the St. Lawrence River. The Great Lakes Pilotage Act of 1960 requires certain ships on these waters to have a registered pilot on board. The Coast Guard oversees the registration of American pilots and supervises private pilotage associations responsible for training new pilots. Hight applied for registration in 2018, but the Pilots Association recommended denial, citing incomplete training and concerns about his temperament. The Coast Guard denied his application after an independent review.Hight challenged the decision in the United States District Court for the District of Columbia, arguing that the Coast Guard acted arbitrarily and capriciously, unconstitutionally delegated authority to the Pilots Association, and violated the First Amendment by requiring him to train with and join the Pilots Association. The district court rejected all claims, finding that the Coast Guard's decision was supported by substantial evidence, including Hight's failure to complete the required training and concerns about his temperament.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Coast Guard's decision was reasonable and supported by the record, as Hight had not completed the required supervised trips on the St. Lawrence River. The court also found that the Coast Guard did not unconstitutionally delegate authority to the Pilots Association, as the association's role was limited to providing advice and gathering facts. Finally, the court determined that Hight's First Amendment claim regarding mandatory association membership was not ripe for review, as he was not yet eligible to join the Pilots Association. The court affirmed the district court's judgment. View "Hight v. DHS" on Justia Law

AdvanFort Company, a maritime security firm based in Virginia, deployed a vessel, the Seaman Guard Virginia, for anti-piracy services in the Red Sea. In October 2013, the vessel docked at the Jeddah Shipyard in Saudi Arabia for repairs by Zamil Offshore Services Company. During the repairs, a fire broke out, which AdvanFort attributed to Zamil's personnel. AdvanFort sued Zamil and the Saudi Ports Authority in a Saudi court in 2014, but the court dismissed AdvanFort's claims and awarded partial damages to Zamil on its countersuit. In 2022, Zamil moved the vessel to a storage yard, claiming it was at risk of sinking, and later informed AdvanFort that it would dispose of the vessel if not retrieved.AdvanFort filed a complaint in the Eastern District of Virginia in July 2023, alleging conversion, breach of bailment, negligence, and gross negligence against Zamil and the Ports Authority. Zamil moved to dismiss the complaint on the grounds of forum non conveniens and lack of personal jurisdiction, arguing that Saudi courts were a more appropriate forum. The Ports Authority did not appear, leading to a default entry against it.The United States District Court for the Eastern District of Virginia dismissed AdvanFort's complaint on the basis of forum non conveniens, finding that Saudi courts were available, adequate, and more convenient for the litigation. The court noted that the relevant events and evidence were located in Saudi Arabia and that the Saudi courts had jurisdiction over both defendants.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court held that the district court did not abuse its discretion in determining that Saudi Arabia was a more convenient forum and that the Saudi courts were both available and adequate for adjudicating AdvanFort's claims. The court also found no error in the district court's denial of limited discovery on forum non conveniens issues. View "AdvanFort Co. v. Zamil Offshore Services Co." on Justia Law

Talos ERT, L.L.C. (Talos) hired DLS, L.L.C. (DLS) to remove corroded piping from an oil-and-gas platform off the Louisiana coast. During the project, a 129-pound pipe fell and struck Walter Jackson, a DLS employee, resulting in his death. Jackson’s widow, Vantrece Jackson, and his son, Y.J., represented by his mother, Anika Warner, sued Talos for wrongful death. The suits were consolidated, and the case proceeded to trial.The jury found Talos 88% at fault for Jackson’s death and awarded significant damages to both plaintiffs. Y.J. was awarded $120,000 in special damages and $20,000,000 in general damages. Mrs. Jackson was awarded $987,930 in special damages and $6,600,000 in general damages. Talos filed a renewed motion for judgment as a matter of law (JMOL) and alternatively moved for a new trial or remittitur. The district court denied the JMOL and new trial motions but granted a partial remittitur, reducing Y.J.’s general damages to $4,360,708.59 and Mrs. Jackson’s to $5,104,226.22. Plaintiffs declined a new trial on damages.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s denial of Talos’s renewed JMOL motion, finding sufficient evidence to support both theories of liability: vicarious liability and independent negligence. The court also upheld the denial of a new trial on liability, noting the jury’s verdict was supported by the evidence.Regarding damages, the court found no abuse of discretion in the district court’s application of the maximum recovery rule for Y.J.’s award, using a factually similar case, Rachal v. Brouillette. However, the court vacated Mrs. Jackson’s general damages award and remanded for redetermination of remittitur, as the district court’s comparison case, Zimko v. American Cyanamid, was not factually similar. The court found no plain error in the alleged prejudicial statements made by Plaintiffs’ counsel during the trial. View "Warner v. Talos ERT" on Justia Law

A tragic boat accident occurred when Edward Barnett, while navigating a coastal river, crashed into a dike, resulting in his and his coworker's deaths. Penny Jo Barnett, his widow, sued the Coast Guard, alleging that their failure to maintain navigational aids caused the crash. She claimed the Coast Guard did not properly maintain the lights that were supposed to warn mariners of the dike’s presence.The United States District Court for the District of South Carolina ruled in favor of the Coast Guard after a bench trial. The court found that the Coast Guard was immune from the allegations under the discretionary function exception to the Suits in Admiralty Act (SIAA). The court also held that the failure to repair one non-working light on the dike did not breach the Coast Guard’s duty to repair aids to navigation in a reasonable time. Additionally, the court concluded that Edward Barnett’s own actions were the sole proximate cause of the accident.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the discretionary function exception applied to the Coast Guard’s decisions regarding the brightness, flash sequence, and background lighting of the navigational aids. The court found no statute, regulation, or policy requiring the Coast Guard to take specific actions to alter or improve these aids. The court also upheld the district court’s finding that Edward Barnett’s actions, including exiting the navigable channel, not using a chart plotter, and traveling at high speed at night, were the sole proximate cause of the crash. Thus, the Coast Guard did not breach any duty under maritime negligence theory, nor did it cause the crash. View "Barnett v. United States" on Justia Law

In this case, a seaman, Magnus Aadland, filed a lawsuit in 2017 against Boat Santa Rita II, Inc. (BSR II) and related parties, alleging that he fell ill while working offshore in 2014 and was owed maintenance and cure, which were not provided. Aadland sought compensatory damages for unpaid maintenance and cure, emotional distress, punitive damages, and attorney's fees.The United States District Court for the District of Massachusetts initially ruled in favor of BSR II, finding that Aadland had reached maximum medical recovery (MMR) by the time of the trial in September 2020 and that BSR II had satisfied its duty of cure. The court also denied Aadland's claims for emotional distress, punitive damages, and attorney's fees.On appeal, the United States Court of Appeals for the First Circuit vacated the District Court's judgment, finding that the District Court had erred in its application of the law, particularly regarding the duty of cure and the applicability of the Fifth Circuit's decision in Gauthier v. Crosby Marine Service, Inc. The First Circuit remanded the case for further proceedings.On remand, the District Court ruled that Aadland had not reached MMR as of September 2020 and that BSR II owed cure in the amount of $605,338.07, which was the amount paid by Aadland's private insurer, Tufts. The court credited BSR II's $400,000 payment to Tufts and $238,374 in advances to Aadland against this amount, resulting in a credit for BSR II. The court again denied Aadland's claims for emotional distress, punitive damages, and attorney's fees.On further appeal, the First Circuit affirmed the District Court's judgment regarding emotional distress damages but vacated the judgment regarding punitive damages and attorney's fees, finding that BSR II's breach of its duty of cure was willful. The case was remanded for the District Court to determine whether punitive damages and attorney's fees should be awarded. The First Circuit also affirmed the District Court's finding that Aadland had not reached MMR as of September 2020 and the setoff amount for BSR II's payment to Tufts. View "Aadland v. Boat Santa Rita II, Inc." on Justia Law

Brian Ranger, a maintenance worker for Alamitos Bay Yacht Club, was injured while performing his duties, which included hoisting and mooring vessels. On August 28, 2018, he slipped and fell while boarding a vessel, resulting in serious injuries. Ranger applied for state workers' compensation and subsequently sued the Club under general maritime law, alleging negligence and unseaworthiness.The Los Angeles County Superior Court sustained the Club's demurrer without leave to amend, concluding that Ranger failed to allege facts implicating federal admiralty jurisdiction. Although the court acknowledged the tort occurred on navigable waters, it found that Ranger did not demonstrate his fall posed more than a fanciful risk to maritime commerce. The Court of Appeal affirmed the decision but on different grounds, holding that the Longshore and Harbor Workers’ Compensation Act (LHWCA) displaced general maritime law, making California’s workers’ compensation scheme Ranger’s exclusive remedy.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that the 1984 amendments to the LHWCA, which exclude certain workers from federal workers' compensation if they are covered by state laws, did not abrogate general maritime remedies for those outside the LHWCA’s scope. The court also determined that California’s workers’ compensation exclusive-remedy provision could not deprive Ranger of his substantive federal maritime rights under the supremacy clause of the federal Constitution. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings to address unresolved issues, including whether Ranger’s claims properly invoked admiralty jurisdiction. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law

Two defendants, Antonio Lemus and Carlos Daniel Canario-Vilomar, were convicted of cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). Lemus was apprehended on December 30, 2021, when U.S. Coast Guard officers intercepted a vessel north of Panama, found cocaine, and determined the vessel was without nationality after Colombia could not confirm its registration. Canario-Vilomar was arrested on December 6, 2021, when a similar vessel was intercepted north of Colombia, and the Dominican Republic could not confirm its registration. Both defendants were charged with conspiracy to possess and distribute cocaine on a vessel subject to U.S. jurisdiction.In the Southern District of Florida, Lemus pled guilty to both counts and was sentenced to 87 months in prison. In the Middle District of Florida, Canario-Vilomar pled guilty to conspiracy, and his motion to dismiss the indictment was denied. He was sentenced to 120 months in prison. Both defendants appealed, arguing that the MDLEA exceeded Congress's authority under the Felonies Clause of the Constitution and that their vessels were not stateless under international law. Canario-Vilomar also argued that his offense occurred in an Exclusive Economic Zone (EEZ), which he claimed was beyond Congress's regulatory authority.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Congress's authority under the Felonies Clause is not limited by international law, affirming that the MDLEA's definition of a "vessel without nationality" and the inclusion of the EEZ within the "high seas" were constitutional. The court also rejected Canario-Vilomar's due process argument, citing precedent that the MDLEA does not require a nexus to the United States for jurisdiction. Consequently, the Eleventh Circuit affirmed the convictions of both defendants. View "USA v. Canario-Vilomar" on Justia Law

The California Air Resources Board (CARB) adopted a regulation in August 2020 to limit emissions from ocean-going vessels while docked at California ports. The Western States Petroleum Association (WSPA) challenged this regulation, arguing that CARB acted arbitrarily and capriciously by setting unfeasible compliance deadlines for emissions control measures. WSPA also claimed that CARB violated the Administrative Procedures Act (APA) by not timely disclosing a commissioned report on tanker emissions and failed to adequately analyze safety hazards and cumulative environmental impacts under the California Environmental Quality Act (CEQA).The Superior Court of Los Angeles County denied WSPA’s petition for a writ of mandate, finding that CARB had the authority to set emissions standards requiring future technology and that WSPA did not prove the necessary technology would not be developed in time. The court also found that CARB substantially complied with the APA’s notice provisions and did not violate CEQA in its environmental analysis.The California Court of Appeal, Second Appellate District, affirmed the lower court’s decision. The appellate court held that CARB’s determination that compliance with the regulation was feasible did not lack evidentiary support. CARB relied on assurances from technology providers that capture and control systems could be adapted for tankers by the compliance deadlines. The court also found that CARB substantially complied with the APA by making the emissions report available before the end of the comment period, allowing WSPA to provide feedback. Finally, the court held that CARB’s environmental analysis under CEQA was adequate, as it provided a general discussion of potential impacts and appropriately deferred more specific analysis to future site-specific reviews. View "Western States Petroleum Ass'n. v. Cal. Air Resources Bd." on Justia Law