Justia Admiralty & Maritime Law Opinion Summaries

A maritime worker was injured while unloading cargo from a vessel managed by Grieg Star AS. The worker, employed by a stevedoring company, fell ten feet when she stepped onto plastic sheeting covering a gap between rolls of cargo in the ship’s hold. The cargo, consisting of large rolls of kraft liner board, had been loaded by longshoremen overseas, and plastic sheeting was used to cover gaps between layers. The injured worker had been assigned to roll up this sheeting during the final phase of unloading. She was aware of the gaps but alleged that the plastic concealed them and appeared to provide fall protection.After the accident, the worker filed a suit in Texas state court against Grieg Star, alleging vessel negligence under the Longshore and Harbor Workers’ Compensation Act, specifically violations of the turnover and active control duties. The case was removed to the United States District Court for the Southern District of Texas. Following discovery, Grieg Star moved for summary judgment, arguing there was no genuine dispute of material fact and that it was entitled to judgment as a matter of law. The district court agreed and granted summary judgment in favor of Grieg Star. The worker appealed.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. It held that the alleged hazard was open and obvious to the worker, so the vessel owed no turnover duty to warn. The court also found that Grieg Star did not exercise active control over the stevedoring operations or the area where the injury occurred, as the stevedore had responsibility for the hold at the time. Accordingly, the Fifth Circuit affirmed the district court’s grant of summary judgment to Grieg Star. View "Renteria v. Grieg Star AS" on Justia Law

A business agreement was made in early 2020 for the rental of a yacht for an event. The agreement involved a payment of $18,280, which was to cover a deposit and a down payment toward the rental fee. The event was canceled due to the COVID-19 pandemic, and the party that made the payment requested a refund. The yacht provider did not return the funds. The party seeking the refund sued under several theories, including unjust enrichment and breach of contract.After mandatory arbitration resulted in an award for the plaintiff, the defendant requested a trial de novo, and the matter proceeded under Nevada’s Short Trial Program. A short trial judge rendered a proposed judgment in favor of the plaintiff. The defendant objected to this proposed judgment, but the short trial judge, after consulting with the Alternative Dispute Resolution Office, ruled on the objection and later denied the defendant’s NRCP 59 motion to alter or amend the judgment, or for a new trial. The district court then entered judgment in favor of the plaintiff, apparently approving the short trial judge’s proposed judgment.On appeal, the Supreme Court of Nevada considered whether a short trial judge has authority to adjudicate objections to a proposed judgment and post-judgment NRCP 59 motions. The court held that under the plain language of NSTR 3(d), only the district court—not a short trial judge—may review and adjudicate objections to proposed judgments and NRCP 59 motions. The court found that the short trial judge exceeded her authority by ruling on these matters. The Supreme Court of Nevada vacated the district court’s judgment and the short trial judge’s post-judgment orders, remanding the case to the district court for further proceedings consistent with its opinion. View "VEGAS AQUA, LLC VS. JUPITOR CORP." on Justia Law

A resident of Puerto Rico suffered work-related injuries in 1994, resulting in permanent total disability. His employer and its insurance carrier were ordered to provide medical care under Section 7 of the Longshore and Harbor Workers’ Compensation Act, as extended by the Defense Base Act. In 2019, a Puerto Rico-licensed physician recommended medical cannabis-infused edibles to treat the petitioner’s chronic pain. The petitioner sought reimbursement for these products from the employer’s insurance carrier, which denied the request.The petitioner then asked the United States Department of Labor’s Office of Administrative Law Judges to order reimbursement, arguing that medical cannabis was a reasonable and necessary treatment. The Administrative Law Judge denied the request, finding that marijuana’s classification as a Schedule I substance under the Controlled Substances Act (CSA) meant it could not have an accepted medical use under federal law. On appeal, the Department of Labor Benefits Review Board affirmed this decision by a 2-1 vote, agreeing that reimbursement was barred by the CSA and rejecting arguments that recent federal appropriations riders or executive actions altered the federal legal status of marijuana.On further appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court held that because marijuana remains a Schedule I substance under the CSA, it cannot be considered a reasonable and necessary medical expense for purposes of reimbursement under the Longshore and Harbor Workers’ Compensation Act. The court found that neither appropriations riders nor recent executive or legislative actions had changed marijuana’s federal classification or its legal status under the Act. Therefore, the court denied the petition for review. View "Garcia v. Department of Labor" on Justia Law

A former ship captain was prosecuted after a fire broke out on his vessel, resulting in the deaths of thirty-four passengers and crew members. The ship, used for recreational diving, had multiple fire safety features and regulatory requirements, including the need for a roving night patrol and crew training in fire response. The captain had extensive maritime experience, but his crew was relatively inexperienced and had not been adequately trained in emergency procedures. On the night of the incident, no one was assigned to patrol for fires, and when the fire was discovered, the crew was unprepared to respond effectively. The captain contacted the Coast Guard but did not use the ship’s public address system to warn those below deck or attempt a rescue, ultimately abandoning ship along with other crew members. All individuals below deck died from smoke inhalation and asphyxiation.The United States District Court for the Central District of California presided over the initial criminal case. The first indictment tracked the language of the seaman’s manslaughter statute but was dismissed by the district court for not alleging gross negligence, which the court believed was required based on prior interpretations of a different manslaughter statute. The government reindicted, alleging gross negligence, and the case proceeded to trial. The jury was instructed that conviction could follow if the captain engaged in “misconduct and/or acted with gross negligence.” The jury found the captain guilty.On appeal, the United States Court of Appeals for the Ninth Circuit held that the seaman’s manslaughter statute, 18 U.S.C. § 1115, requires only ordinary negligence, not gross negligence. The court further concluded that, even if the jury instruction’s use of “misconduct” was erroneous, any such error was harmless because the instructions repeatedly referenced the higher gross negligence standard, the prosecution did not argue for a lower standard, and overwhelming evidence supported the conviction. The judgment was affirmed. View "USA V. BOYLAN" on Justia Law

Javier Hernandez was a participant in a transnational criminal operation that smuggled Cuban migrants into Mexico for eventual entry into the United States. His primary role involved stealing boats from Southwest Florida, which he delivered to co-conspirators in Mexico. These vessels were used to transport migrants from Cuba or were sold to support the smuggling enterprise, including bribing law enforcement. Hernandez also transported stolen vehicles to Mexico for similar purposes. He was compensated for each delivery and admitted to earning substantial profits from these activities.Federal authorities identified Hernandez through investigative techniques including cell-site location tracking and the recovery of his cell phone, which had been seized by Mexican authorities. The government obtained and executed a warrant to search his phone, extracting relevant data. After initial technical difficulties, a second extraction was performed after the warrant’s nominal expiration date but while the phone was still in government custody. Hernandez was indicted in the United States District Court for the Southern District of Florida on five counts, including conspiracy to encourage unlawful entry, transportation of stolen vessels, trafficking in vehicles with altered VINs, and money laundering. He moved to suppress the evidence from the second extraction, but the district court denied the motion, applied several sentencing enhancements, and imposed a sentence of ninety-five months.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the second extraction did not violate Federal Rule of Criminal Procedure 41 or the Fourth Amendment, as Rule 41(e)(2)(B) allows for off-site copying and review of electronic information after the warrant period. The court also found that even if there were a procedural violation, suppression would not be warranted due to the agents’ good faith and lack of prejudice. The court determined that the evidence was sufficient to sustain all convictions and found no reversible error in the sentencing calculations or guideline enhancements. The Eleventh Circuit affirmed the district court’s judgment. View "USA v. Hernandez" on Justia Law

Tammy Knieling worked as a chef and deck hand on a chartered boat owned by William Poston and captained by Don Fung Fook. During a voyage, Knieling broke and dislocated her left middle finger while following an order to release the dinghy line. Despite the injury, she continued her work and did not miss any wages. After returning ashore, she was treated for the injury, which resulted in permanent loss of some range of motion. A medical expert suggested possible future treatments, including exercises, injections, and potentially surgery, but could not confirm if she had reached maximum medical improvement or if further treatments would be necessary or effective.Knieling brought suit against both Fook and Poston in the District Court of the Virgin Islands, which conducted a bench trial. The District Court dismissed her claims against Fook but found Poston liable under the Jones Act for negligence, awarding past medical expenses and pain and suffering. The court also found Poston liable for medical expenses under admiralty law but determined Knieling had already recovered these. It declined to award her living expenses, punitive damages, or attorney’s fees, finding she neither took time off work nor incurred additional living costs, and that Poston’s delay in payment was not in bad faith.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that Knieling could not recover maintenance because she did not miss work or incur additional living expenses. The court also held that her claim for future medical expenses was too speculative, as there was insufficient evidence regarding her need for further treatment. However, if she requires curative treatment in the future, she may bring a new claim. Finally, the court affirmed the denial of punitive damages, attorney’s fees, and costs due to the absence of bad faith by the defendants. View "Knieling v. Fook" on Justia Law

Fieldwood Energy operated an offshore platform near Louisiana and contracted with United Fire and Safety to provide fire watch services for repairs. Fieldwood also separately chartered a liftboat from Aries Marine to support the work, which included housing and crane services for the contractors. During the project, the liftboat listed and capsized, leading to personal injuries for a United Fire employee. Aries Marine, facing liability claims, sought indemnification from United Fire based on a cross-indemnification clause in the 2013 Master Services Contract (MSC) between Fieldwood and United Fire.The United States District Court for the Eastern District of Louisiana considered cross-motions for summary judgment on whether the MSC was a maritime contract. The district court found that the contract was not maritime in nature, applying Louisiana law via the Outer Continental Shelf Lands Act (OCSLA), which incorporates the law of the adjacent state unless federal maritime law applies. Louisiana’s Oilfield Anti-Indemnity Act invalidated the indemnity provisions. Aries’s motions for reconsideration were denied, leading to this appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court agreed that the MSC did not require or contemplate that a vessel would play a substantial role in the contracted fire watch services. It found that only Fieldwood, not United Fire, expected the liftboat’s substantial involvement, and that such a shared expectation was necessary under circuit precedent to create a maritime contract. Because the parties did not share this expectation, the contract was not maritime, and Louisiana law voided the indemnity provisions. The Fifth Circuit affirmed the district court’s judgment. View "Aries Marine v. United Fire & Safety" on Justia Law

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