Justia Admiralty & Maritime Law Opinion Summaries

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

Havana Docks Corporation, a U.S.-based entity, obtained a usufructuary concession from the Cuban Government in 1928, granting it the right to develop and operate docks at the Port of Havana until 2004. This concession included a government promise of compensation if expropriation occurred before expiration. In 1960, following Fidel Castro’s rise to power, the Cuban Government seized control of the docks without compensating Havana Docks, prematurely terminating its concession. The Foreign Claims Settlement Commission later certified Havana Docks’ loss as approximately $9 million plus interest. Decades later, from 2016 to 2019, four major cruise lines used the Havana docks to transport passengers to Cuba, paying Cuban government-affiliated entities for access.Havana Docks sued the cruise lines under the Cuban Liberty and Democratic Solidarity Act (LIBERTAD Act) in the United States District Court for the Southern District of Florida. The cruise lines argued they could not be liable because Havana Docks’ concession would have expired in 2004 even without confiscation. The District Court disagreed, found for Havana Docks, and ordered each cruise line to pay over $100 million. The United States Court of Appeals for the Eleventh Circuit reversed this judgment, holding that liability under the Act required the defendant’s conduct to interfere with a property interest the plaintiff would have had absent confiscation, and since Havana Docks’ concession would have expired before the cruise lines’ conduct, no liability attached.The Supreme Court of the United States reviewed the case and disagreed with the Eleventh Circuit’s analysis. The Court held that, under the Act, liability attaches to anyone who traffics in physical property confiscated by the Cuban Government, not just property interests. It concluded that the cruise lines’ use of the docks constituted trafficking in confiscated property to which Havana Docks owns a claim, regardless of when Havana Docks’ concession would have expired. The Supreme Court vacated the Eleventh Circuit’s decision and remanded the case for further proceedings. View "Havana Docks Corp. v. Royal Caribbean Cruises, Ltd." on Justia Law

A seaman was severely injured while working on an offshore supply vessel operated by his employer. Following his injury, the employer provided both mandatory and supplemental benefits, including housing and transportation. Six months after the incident, the employer’s executives presented the seaman with an agreement offering continued supplemental benefits in exchange for his commitment to arbitrate any future claims against the company. The agreement included a delegation clause stating that any disputes about the validity, interpretation, or application of the agreement would be resolved by an arbitrator. The seaman signed, acknowledging he had the opportunity to consult an attorney but later alleged he felt pressured and feared losing benefits if he did not sign.The seaman filed suit in the United States District Court for the Eastern District of Louisiana, alleging negligence and seeking a declaration that the agreement and its arbitration provisions were invalid due to fraud, duress, and his medical condition. The employer moved to compel arbitration and to stay the litigation, arguing that the delegation clause required an arbitrator to decide issues of enforceability. The district court denied the motion without prejudice and allowed limited discovery on the enforceability of the agreement, concluding it must decide if a valid arbitration agreement existed.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court erred by failing to enforce the delegation clause. The appellate court found the seaman’s arguments challenged the agreement as a whole, not the delegation clause specifically. Under Supreme Court precedent, such challenges must be resolved by an arbitrator when a valid delegation clause exists and is not directly challenged. The Fifth Circuit vacated the district court’s order and compelled arbitration, remanding for further proceedings consistent with this holding. View "Hill v. Jackson Offshore Holdings" on Justia Law

A Dominican Republic citizen was operating a high-speed vessel in international waters off Puerto Rico with two others when a United States Coast Guard helicopter and cutter approached. After issuing warning shots that failed to stop the vessel, the Coast Guard fired live rounds at the engine, and two bullets struck the plaintiff’s left arm, causing serious, permanent injury. The plaintiff remained on deck for thirty minutes before receiving medical attention and was later airlifted to a hospital in San Juan.After his administrative claim under the Federal Tort Claims Act (FTCA) was denied, the plaintiff filed suit in the United States District Court for the District of Puerto Rico. He initially brought constitutional claims against individual Coast Guard officers and a tort claim against the federal government under the FTCA’s law enforcement proviso, but later voluntarily dismissed the constitutional claims. The government moved to dismiss the FTCA claim, arguing the claim was subject to admiralty law and thus exclusively governed by the Suits in Admiralty Act (SIAA). The magistrate judge recommended dismissal, concluding the FTCA did not apply because the SIAA provided the exclusive remedy. The judge further recommended denying the plaintiff’s request to amend his complaint to add an SIAA claim because it would be time-barred. The district court adopted these recommendations and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the First Circuit affirmed. The court held that the plaintiff’s claim arose under maritime jurisdiction and was therefore governed exclusively by the SIAA, not the FTCA. Because the FTCA expressly excludes claims for which a remedy is provided by the SIAA, the plaintiff could not proceed under the FTCA, even if his SIAA claim was time-barred. The dismissal with prejudice was affirmed. View "Lantigua-Nunez v. US Coast Guard" on Justia Law