Justia Admiralty & Maritime Law Opinion Summaries

A seaman employed by a transportation district suffered injuries while working on a ferryboat. The seaman and his wife initiated a lawsuit against the district, asserting several maritime claims, including negligence under the Jones Act, unseaworthiness, and maintenance and cure. The wife sought damages for loss of consortium based on the injuries her husband sustained, alleging that the vessel’s condition was unsafe and unseaworthy.The Superior Court of San Francisco City and County reviewed the case. The district filed a demurrer challenging the wife’s loss of consortium claim, arguing that neither the Jones Act nor general maritime law allowed such a remedy. The plaintiffs opposed, contending that general maritime law provided for loss of consortium and that the Jones Act did not bar this type of recovery. The trial court sustained the demurrer without leave to amend, concluding that neither the Jones Act nor general maritime law authorizes recovery for loss of consortium in this context.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the decision. On de novo review, the appellate court affirmed the lower court’s ruling. It held that loss of consortium is not available under the Jones Act for non-fatal injuries, as the statute limits recovery to pecuniary loss and authorizes only the injured seaman (not the spouse) to bring a claim. The court also applied the framework from United States Supreme Court cases—particularly The Dutra Group v. Batterton, Miles v. Apex Marine Corp., and Atlantic Sounding v. Townsend—and found no historical basis for allowing loss of consortium under general maritime law for personal injury unseaworthiness claims. The court thus affirmed the dismissal of the loss of consortium claim. View "Simerley v. Golden Gate Bridge Highway and Transp. Dist." on Justia Law

Two individuals, acting as relators on behalf of the United States, brought a qui tam action against several corporate and individual defendants. They alleged that the defendants engaged in a fraudulent scheme to secure fishing endorsements by misrepresenting the citizenship status of the entity applying for those endorsements. This misrepresentation allowed an ineligible non-U.S. entity to obtain endorsements and harvest menhaden, a commercially valuable fish, from U.S. waters. The relators claimed that these actions violated the False Claims Act by inducing federal authorities to issue fishing endorsements based on false information and by enabling the defendants to illegally profit from harvesting fish to which they were not entitled.The United States District Court for the Southern District of New York reviewed the amended complaint and granted the defendants’ motion to dismiss. The court found that the relators could not demonstrate that defendants made a claim for property as required under several subsections of the False Claims Act. It also concluded that the relators failed to show the defendants avoided or decreased any established obligation to pay money to the United States, as necessary for a reverse false claim. The district court further denied the relators’ request for leave to file an additional amended complaint.The United States Court of Appeals for the Second Circuit considered the relators’ appeal. The court held that wild fish in public waters are not “property” under the False Claims Act, foreclosing the first three causes of action. It also determined that unassessed civil penalties for alleged violations of the American Fisheries Act do not constitute an “obligation to pay” under the Act, defeating the reverse false claim. Finally, the Second Circuit concluded the district court did not abuse its discretion in denying leave to amend, and affirmed the district court’s judgment. View "United States ex rel. Chiles v. Cooke Inc." on Justia Law

Coast Guardsmen intercepted two stateless vessels in international waters, each carrying large quantities of cocaine traveling from Colombia to Mexico. Alonso Pineda-Torres, a Colombian citizen and resident, was involved in planning and preparing these smuggling operations, including paying crewmembers and assisting with a launch from Colombia. After his extradition to the United States, he was indicted under the Maritime Drug Law Enforcement Act for conspiracy to distribute and possess cocaine on a vessel subject to U.S. jurisdiction.In the United States District Court for the Middle District of Florida, Pineda-Torres initially pleaded not guilty, but later entered a plea agreement, admitting involvement in the operation. He moved to dismiss the indictment, arguing the court lacked jurisdiction because his conduct occurred abroad and he was not captured in international waters. The district court denied his motion, and he subsequently pleaded guilty.The United States Court of Appeals for the Eleventh Circuit reviewed the constitutionality of the statute as applied to Pineda-Torres. He argued the statute was invalid because his acts lacked a nexus to the United States and occurred solely in Colombia. The Eleventh Circuit rejected these arguments, relying on its precedent that the Act’s extraterritorial reach is supported by universal and protective principles, and that no nexus to the United States is required. The court held that, even if the Felonies Clause alone did not provide authority, the Necessary and Proper Clause empowered Congress to criminalize conspiracies to commit drug trafficking on the high seas, including land-based conduct like Pineda-Torres’s. Accordingly, the Eleventh Circuit affirmed the conviction, holding Congress had constitutional authority to punish this kind of conspiracy involving drug trafficking in international waters. View "USA v. Pineda-Torres" on Justia Law

Two individuals were bowfishing on Lake Guntersville in Alabama when their boat collided with an unmarked, partially submerged duck blind, resulting in severe injuries. The duck blind, built by unknown persons prior to 2007, was affixed to land owned by the Tennessee Valley Authority (TVA), a federally owned corporation. The United States Coast Guard, the U.S. Army Corps of Engineers, and the TVA all have regulatory responsibilities over the lake, which is a navigable waterway. The plaintiffs alleged negligence and wantonness, claiming that the United States and the TVA failed to mark, remove, or warn about the hazard.The plaintiffs filed suit in the United States District Court for the Northern District of Alabama under two statutes: the Suits in Admiralty Act (SAA) and the TVA Act. Defendants moved to dismiss, arguing that the discretionary-function exception from the Federal Tort Claims Act (FTCA) shielded them from liability. The district court granted the motion, finding that the SAA's waiver of sovereign immunity was subject to the FTCA’s discretionary-function exception and that the conduct at issue was discretionary.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal of all claims against the United States, holding that binding circuit precedent recognizes a discretionary-function exception under the SAA, which bars such claims. However, the Eleventh Circuit reversed the dismissal of the claims against the TVA under the TVA Act. The court held that the TVA’s sue-and-be-sued clause is not subject to the discretionary-function exception, allowing the plaintiffs’ claims against the TVA to proceed. The case was remanded for further proceedings against the TVA only. View "Jones v. USA" on Justia Law

In May 2019, a woman was severely injured during a scuba diving trip in Belize after an employee of a Belizean dive shop, who was not a certified dive master, pushed her off a boat owned by the company. As she entered the water, she was caught by the boat’s engaged propellers, causing significant injuries to her foot, ankle, and knee. She, along with her husband and son, filed a lawsuit in the United States District Court for the District of Massachusetts in August 2020, alleging maritime claims and asserting federal jurisdiction. The Belizean company was served under international procedures, and its founder acknowledged receipt. The company did not participate in the proceedings, leading the court to enter a default judgment against it in June 2021, and, after an evidentiary hearing, award over six million dollars in damages in February 2022.After the judgment, the plaintiff sought to enforce it in Belize, resulting in further default proceedings and an order to pay over seven million dollars, with enforcement actions against the company’s assets. The company eventually contested the judgment in Belize, and the Belizean court later set aside its own default judgment. In February 2024, about two years after the original U.S. judgment and nineteen months after the enforcement effort in Belize began, the company first appeared in the Massachusetts case, seeking to vacate the default judgment under Federal Rule of Civil Procedure 60(b)(4), arguing lack of jurisdiction.The United States Court of Appeals for the First Circuit reviewed whether the company’s motion to vacate was timely under Rule 60(c)(1), which requires such motions to be made “within a reasonable time.” Citing recent Supreme Court precedent, the First Circuit held that this timing requirement applies even to claims that a judgment is void for lack of jurisdiction. The court concluded the company’s nearly two-year delay was unreasonable and affirmed the district court’s denial of the motion. View "Flaherty v. Amigos Del Mar LTD." on Justia Law

A man was stopped by South Dakota wildlife conservation officers while boating on the Missouri River between South Dakota and Nebraska in July 2024. The officers noticed possible impairment and, after a field sobriety test, arrested him for boating under the influence and other offenses. The events in question took place near the Nebraska shoreline, beyond the centerline of the river’s designed channel.The defendant moved to dismiss the charges in the Magistrate Court of the First Judicial Circuit, Union County, South Dakota, arguing the state lacked jurisdiction because the incident happened on the Nebraska side of the river. After an evidentiary hearing, the magistrate court found that the arrest occurred on the Nebraska side, and concluded that South Dakota’s statutes giving conservation officers jurisdiction to the furthermost shoreline were preempted by the federally approved 1989 South Dakota-Nebraska Boundary Compact, which fixes the state boundary at the centerline of the Missouri River. The magistrate court dismissed the case for lack of jurisdiction.The State of South Dakota sought appellate review. The Supreme Court of the State of South Dakota first determined that the State’s petition for intermediate appeal was timely and that it had appellate jurisdiction. The Supreme Court held that the magistrate court did not abuse its discretion by receiving testimony and evidence to resolve the jurisdictional issue. The Supreme Court further held that, based on federal law and the 1989 Compact, South Dakota does not have concurrent jurisdiction over the Missouri River beyond the centerline of the designed channel unless there is an agreement or reciprocal legislation with Nebraska, which does not exist. As a result, the Supreme Court affirmed the magistrate court’s order dismissing the charges for lack of jurisdiction. View "State v. Ogden" on Justia Law

The case concerns a worker who was employed as a ship painter at a shipyard in Indiana for twelve years. After being laid off in 2017, he filed a claim for workers’ compensation under the Longshore and Harbor Workers’ Compensation Act, alleging that he experienced breathing difficulties due to prolonged exposure to various lung irritants during his employment, including fumes from paints, paint thinners, sandblasting materials, and other chemicals. He had a history of health issues, including asthma, COPD, and emphysema, and was a longtime smoker who switched to vaping in 2015. Medical evidence was presented by both the claimant and the employer, with dueling expert reports on whether workplace exposures contributed to his lung conditions.The Department of Labor administrative law judge (ALJ) conducted a formal hearing. The ALJ found the claimant had suffered harm and that workplace conditions could have caused it, entitling him to a statutory presumption of causation. The employer rebutted this presumption, but after considering the evidence, the ALJ credited the claimant’s expert and concluded that workplace exposures contributed to his lung impairment. The ALJ awarded permanent partial disability benefits and medical expenses. The Office of the District Director later granted a reduced attorney’s fee award. The Benefits Review Board affirmed both the ALJ’s decision and the fee award, finding the factual and legal conclusions rational and supported by substantial evidence.The United States Court of Appeals for the Seventh Circuit reviewed the ALJ and District Director’s decisions directly. Applying the substantial evidence standard, the court held that the ALJ’s findings and conclusions regarding disability, causation, and the extent of impairment were supported by the record and consistent with applicable law. The court also found the employer’s challenge to the fee award waived for lack of record support and legal citation. The petition for review was denied, affirming the Board’s decision. View "Jeffboat, Inc. v Director, OWCP" on Justia Law

A freight service company chartered two barges to a third party, Work Cat, under an agreement that included a “no-lien” clause, prohibiting the charterer from incurring liens on the barges. Work Cat, in turn, chartered two tugboats from another company to tow the barges. While Work Cat initially paid for the tug services, it defaulted on the majority of payments and eventually filed for bankruptcy. The tug owner, seeking to recover unpaid invoices, filed maritime lien notices against the barges and demanded payment from the original barge owner, who refused, arguing that the “no-lien” clause prevented such a lien.The United States District Court for the Eastern District of Louisiana held a bench trial. It determined that the tug owner had valid maritime liens against both barges for the value of towage services provided, but excluded the costs of fuel and lubricants. The district court initially awarded attorney’s fees to the tug owner but later reversed this decision, ordering each party to bear its own legal costs. Both parties appealed, challenging the existence, scope, and value of the liens, as well as the award of attorney’s fees.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It held that a maritime lien attached to the barges because the tug owner provided necessary services without actual knowledge of the “no-lien” clause at the time the towage contract was executed. The court clarified that actual knowledge of such a clause, not constructive knowledge or a duty to investigate, is required to defeat a maritime lien under current law. The value of the lien properly included all towage services but excluded fuel and lubricant costs. The appellate court also found no abuse of discretion in the district court’s denial of attorney’s fees and its award of prejudgment interest. View "Trailer Bridge v. LA Intl Marine" on Justia Law

The United States government brought a civil forfeiture action against a luxury superyacht, alleging that it was beneficially owned by a Russian national subject to U.S. sanctions. Two claimants, an individual and his company, asserted that they—not the sanctioned individual—owned the yacht, both legally and beneficially. The government, however, argued that these claimants were mere straw owners holding title on behalf of the sanctioned individual and therefore lacked constitutional standing to contest the forfeiture.The United States District Court for the Southern District of New York held an evidentiary hearing to resolve factual disputes regarding the claimants’ standing. The court found, by a preponderance of the evidence, that the claimants had relinquished all meaningful ownership and control over the yacht through a memorandum of agreement executed in September 2021. As a result, the court concluded that the claimants were only bare title holders, acting as straw owners, and lacked Article III standing to object to the forfeiture. The court granted the government’s motion to strike the claim and entered default and final judgments of forfeiture when no other claims were filed.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Second Circuit affirmed, holding that the claimants’ legal title alone did not establish standing where the evidence showed they retained no substantive ownership interest after the September 2021 agreement. The court also upheld the district court’s exclusion of a hearsay declaration and concluded there was no procedural error in the conduct of the evidentiary hearing. The judgment of forfeiture was affirmed. View "United States v. The M/Y Amadea" on Justia Law

SLT Imports, a New Jersey company, agreed to finance the importation of goods for Krishna Food Corp. from Bikaji Foods International in India, using SAR Transport Systems as the maritime carrier. Under the arrangement, Krishna would pay SAR by drawing from SLT’s bank facility, and SAR was required to release cargo only upon presentation of an endorsed bill of lading (BOL). SLT later discovered that SAR had delivered goods to Krishna without receiving endorsed BOLs, instead accepting letters of indemnity. SLT alleged that SAR breached the contract and committed fraud in the execution by issuing BOLs with terms it did not intend to honor.The U.S. District Court for the District of New Jersey granted SAR’s motion for judgment on the pleadings, dismissing SLT’s breach-of-contract claim as waived and time-barred under the Carriage of Goods by Sea Act (COGSA), and rejecting SLT’s fraud-in-the-execution claim. The District Court found that SLT failed to allege facts establishing fraud in the execution, and that even if it had, the claim was barred by COGSA’s one-year statute of limitations. The Court also held that the deviation doctrine and equitable estoppel did not apply. SLT’s motion for reconsideration was denied.On appeal, the U.S. Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. It held that SLT did not adequately plead fraud in the execution, as the allegations amounted to breach of contract rather than fraud. The Third Circuit further concluded that SLT’s claim was time-barred by COGSA’s one-year limitation period and that neither the deviation doctrine nor equitable estoppel could circumvent this bar. The Court affirmed the judgment of the District Court, including the denial of leave to amend and the denial of reconsideration. View "SLT Imports Inc v. SAR Transport Systems Pvt Ltd" on Justia Law