Justia Admiralty & Maritime Law Opinion Summaries

In the case involving Williams Sports Rentals Inc. (WSR) and Marian Latasha Willis, the United States Court of Appeals for the Ninth Circuit ruled on the scope of an injunction under the Shipowner’s Limitation of Liability Act. The case stemmed from a fatal accident involving a jet ski owned by WSR. Anticipating a lawsuit, WSR filed a complaint under the Limitation Act, which allows a vessel owner to limit its liability for accidents. The district court granted an injunction against all other lawsuits related to the accident, and the case reached the Ninth Circuit after the district court reinstated the injunction when new claims arose. The Ninth Circuit held that the district court had the authority to grant an injunction since the limitation fund was insufficient to cover all pending claims, but found the injunction to be overly broad. The court ruled that under the Anti-Injunction Act, the district court could only bar claims against the owner (WSR), not claims against other parties. Therefore, the court vacated and remanded the case with instructions to narrow the injunction so that it only barred claims against WSR. View "Williams Sports Rentals Inc. v. Willis" on Justia Law

In this case before the United States Court of Appeals for the Fifth Circuit, the central issue was whether a contract for the inspection and repair of lifeboats on an oil platform, located on the Outer Continental Shelf, could be considered a maritime contract. The relevance of this classification was that it would determine whether indemnity might be owed by one corporate defendant, Palfinger Marine USA, Inc., to another, Shell Oil Company, for payments to third parties. The lower district court had ruled that the contract was not maritime. However, the Court of Appeals disagreed, finding that the contract was indeed a maritime one. The case was related to a tragic accident in 2019 when a lifeboat detached from an oil platform, resulting in the deaths of two workers and injury to another. The platform was owned and operated by Shell Oil Company and its affiliates. The lifeboats were serviced by Palfinger Marine USA, Inc. under a contract which included indemnity provisions. After the accident, lawsuits were filed against both companies by the injured worker and the families of the deceased workers. These claims were settled separately, but Palfinger's claim for indemnity from Shell under the contract was preserved for appeal. The decision of the district court to classify the contract as non-maritime was reversed and remanded for further proceedings. The court held that the contract was maritime, as it was related to the repair and maintenance of lifeboats facilitating offshore drilling and production of oil and gas, which constituted maritime commerce. The lifeboats were found to play a substantial role in the contract, making it a traditionally maritime contract. View "Palfinger Marine U S A v. Shell Oil" on Justia Law

In this case, Trey Wooley filed a state court action against N&W Marine Towing (N&W) and others based on injuries he suffered while serving as a deckhand on the Mississippi River. The United States Court of Appeals for the Fifth Circuit held that Wooley had improperly joined N&W in the state court action in violation of a district court's stay order and the Limitation of Liability Act of 1851, which effectively ceased all claims and proceedings against N&W outside of a federal limitation action that N&W had previously filed. Therefore, N&W was dismissed as a defendant in the state court action. The court further held that, after dismissing N&W, there were no live claims remaining in the state court action because Wooley had previously settled his claims against the other defendants. Consequently, the court severed Wooley's state court action from the limitation action and dismissed it without prejudice. The court retained jurisdiction over the limitation action but stayed it to allow Wooley to pursue any viable claims against N&W in state court. The court concluded that the district court properly denied Wooley's motion to remand, as it had diversity jurisdiction over the case once N&W was dismissed. View "Wooley v. N&W Marine Towing" on Justia Law

In this case, Defendant-Appellee Martin Andersson purchased an insurance policy for his vessel from Plaintiff-Appellant Great Lakes Insurance SE. The vessel ran aground off the coast of the Dominican Republic, and Great Lakes brought a declaratory judgment action to determine coverage under the policy. Andersson filed counterclaims for breach of contract and equitable estoppel. Great Lakes' motion for summary judgment was denied, and Andersson was granted partial summary judgment on his breach of contract claim. Great Lakes appealed, claiming the district court erred in refusing to apply the policy's definition of seaworthiness.The United States Court of Appeals for the First Circuit held that under the absolute implied warranty of seaworthiness, the insured vessel must be seaworthy at the policy's inception, and if not, the policy is void. The court affirmed the district court's ruling, stating that Great Lakes' argument that the absolute implied warranty required the vessel to carry up-to-date charts for all geographic areas covered by the policy in order to be considered seaworthy was unsupported by admiralty case law and was unreasonable.Additionally, the court held that Great Lakes' argument that the express terms of the policy required updated paper charts for every location that could be navigated under the entirety of the policy coverage area was unsupported by the express language of the policy itself. The court found no precedent supporting the claim that updated paper charts for every location covered by the policy were required to be onboard the vessel at the inception of the policy. As a result, the Court of Appeals affirmed the district court's decision in favor of Andersson. View "Great Lakes Insurance SE v. Andersson" on Justia Law

The United States Court of Appeals for the Eleventh Circuit affirmed the judgment of the United States District Court for the Middle District of Florida. The case involved Asdrubal Quijada Marin and Juan Carlos Acosta Hurtado, two Venezuelan nationals who were apprehended by the United States Coast Guard in the Caribbean Sea. They were convicted after a bench trial for conspiracy to possess with intent to distribute five kilograms or more of cocaine while aboard a vessel subject to the jurisdiction of the United States and possession with intent to distribute five kilograms or more of cocaine on a vessel subject to the jurisdiction of the United States, pursuant to the Maritime Drug Law Enforcement Act.On appeal, Marin and Acosta Hurtado challenged the court's jurisdiction, arguing that the indictment should have been dismissed for lack of jurisdiction and the evidence should have been suppressed due to violation of their Fourth Amendment rights. They also contended that their detention at sea for 48 days prior to indictment constituted unnecessary delay and outrageous government conduct.The Court of Appeals held that the District Court properly exercised jurisdiction over Marin and Acosta Hurtado under the Maritime Drug Law Enforcement Act because Cameroon, the flag nation of the vessel, had consented to United States jurisdiction over the crew of the vessel. It also held that the Northland’s stop and search of the Zumaque Tracer did not violate the Fourth Amendment, so the District Court did not err in denying the motion to suppress evidence based on a Fourth Amendment violation. The Court also held that the District Court did not err in denying Acosta Hurtado’s motion to dismiss based on unnecessary delay arguments. Lastly, the Court held that Acosta Hurtado's claim of outrageous government conduct was meritless. View "USA v. Hurtado" on Justia Law

In this case, a law firm, Thompson, MacColl & Bass, LLC, P.A. (TM&B), was sued by its former client, ST Engineering Marine, Ltd. (STEM), for professional negligence. STEM owned a vessel that was arrested due to several entities, including Sprague Operating Resources, LLC (Sprague), asserting maritime liens for unpaid services. STEM had sought advice from TM&B to analyze these lien claims. TM&B advised STEM that Sprague's lien was valid and should be paid. Acting on this advice, STEM paid Sprague and subsequently sued TM&B, alleging that TM&B's advice was negligent as it failed to consider the unsettled state of relevant maritime lien law.The United States Court of Appeals for the First Circuit affirmed the decision of the United States District Court for the District of Maine, which had found in favor of STEM. The Court of Appeals held that TM&B breached its duty of care to STEM by failing to conduct adequate legal research and by not appropriately counseling STEM about the uncertainty of Sprague's lien claim. The court also found that TM&B's negligence was the actual and proximate cause of STEM's loss, concluding that STEM would have prevailed in contesting Sprague's lien claim but for TM&B's erroneous advice. The court ordered TM&B to pay STEM $261,839.04 in damages. View "ST Engineering Marine, Ltd. v. Thompson, MacColl & Bass, LLC, P.A." on Justia Law

In a collision between two vessels on the Mississippi River, the United States Court of Appeals for the Fifth Circuit ruled that Louisiana law, not general maritime law, governs the burden of proof for the pilot's error.On January 3, 2019, the M/V STRANDJA, piloted by Captain Robert Johnson, drifted from its anchorage into the middle of the river, colliding with the M/V KIEFFER E. BAILEY, owned by Marquette Transportation Company Gulf-Inland LLC. The collision caused damage to both vessels. Marquette brought claims against STRANDJA's owner, Balkan Navigation Ltd, and manager, Navigation Maritime Bulgare JSC (collectively referred to as "Balkan"), alleging their negligence caused the collision.A jury found that Marquette was not negligent and that Balkan and Captain Johnson were each 50% at fault. The jury awarded Marquette $114,000 in damages and awarded Balkan $0 in damages. Both Balkan and Captain Johnson appealed the judgment.The Fifth Circuit affirmed the judgment that Marquette was not negligent, and therefore not liable for the accident. However, the court found that the district court erred in instructing the jury to apply general maritime law, which only requires a finding of ordinary negligence by a preponderance of the evidence, to the claim against Captain Johnson. Instead, the court held that Louisiana law, which requires clear and convincing evidence of gross negligence or willful misconduct, should have been applied.As a result, the court vacated the judgment against Balkan and Captain Johnson and remanded the case for a new trial, applying the correct standard of proof under Louisiana law. The court also ordered Marquette to amend its complaint within 14 days to allege admiralty jurisdiction as the jurisdictional basis for its claim against Balkan. View "Marquette Transportation Company Gulf-Inland, L.L.C. v. Navigation Maritime Bulgare" on Justia Law

In 2023, the State of Texas, under the direction of Governor Greg Abbott, installed a floating barrier in the Rio Grande near Eagle Pass, Texas. The United States government filed a civil enforcement action against Texas, alleging that the installation of the barrier violated the Rivers and Harbors Appropriation Act of 1899 (“RHA”). The United States sought a preliminary injunction, which was granted by the district court, ordering Texas to cease work on the barrier and to relocate it to the Texas riverbank. Texas appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The Court of Appeals found that the United States demonstrated a likelihood of success on the merits of its RHA claims. The court determined that the part of the Rio Grande where the barrier was installed was a navigable waterway and that the barrier constituted an obstruction to this waterway. The court also found that the barrier was a structure as defined by the RHA and that it had been constructed without necessary authorization.In addition, the court found that the United States had demonstrated that it was likely to suffer irreparable harm in the absence of preliminary relief. The court noted that the barrier strained diplomatic relations with Mexico, interfered with the ability of the International Boundary and Water Commission to implement the provisions of a treaty concerning the allocation of waters in the Rio Grande, and posed a risk to human life.The court also held that the balance of equities favored the United States and that the issuance of a preliminary injunction was in the public interest. Specifically, the court noted that the barrier threatened navigation and federal government operations on the Rio Grande, and also posed a potential threat to human life.Taking all of these factors into account, the court ruled that the district court did not abuse its discretion in granting a preliminary injunction ordering Texas to cease work on the barrier and to relocate it. View "USA v. Abbott, No. 23-50632 (5th Cir. 2023)" on Justia Law

Vigor Marine, LLC  hired Western to tow a drydock, which was damaged in a storm off the coast of California. In an attempt to bring the drydock to shelter in Monterey Bay, Western’s tug towed the drydock into the Monterey Bay National Marine Sanctuary, where it capsized and sank. Western sued Vigor, seeking recovery of the towing fee under its contract with Vigor and a declaratory judgment that it would not be liable for any damages or penalty sought by the government under the National Marine Sanctuaries Act (NMSA). Vigor counterclaimed for breach of contract and negligence by Western.   The Ninth Circuit affirmed in all respects but one the district court’s judgment after a bench trial in an admiralty action brought by Western against Vigor Marine; vacated an award of prejudgment interest; and remanded. The panel affirmed the district court’s grant of partial summary judgment to Vigor on the grounds that Western was negligent as a matter of law in allowing the drydock to sink in the Sanctuary, and there were no material issues of fact regarding Western’s lack of awareness of the legal consequences of allowing the drydock to sink there. After a trial on the remaining claims, the district court denied both parties’ contract claims and held that both had been negligent. Vacating the district court’s award of prejudgment interest on the $40,000 award against Western, the panel held that interest should run from the date of Vigor’s expenditures rather than the date the drydock sank. The panel remanded to allow the district court to recalculate the prejudgment interest based on the correct date. View "WESTERN TOWBOAT COMPANY V. VIGOR MARINE, LLC" on Justia Law

N&W Marine Towing (N&W) filed in federal district court a verified complaint in limitation (the Limitation Action), pursuant to the Limitation of Liability Act of 1851 (Limitation Act) and Rule F of the Supplemental Rules for Certain Admiralty and Maritime Claims. The complaint filed in N&W’s Limitation Action alleged that on February 29, 2020, the M/V Nicholas, which is owned by N&W, was towing six barges up the Mississippi River when the wake of a cruise ship, the Majesty of the Seas, caused one of the Nicholas’s face wires to break. After dismissing N&W from the case, no claims remained in the State Court Petition because Wooley had settled his claims against the other defendants. Therefore, the district court severed Wooley’s State Court Petition from the Limitation Action and dismissed it. The district court retained jurisdiction over the Limitation Action but stayed and administratively closed it to allow Wooley to pursue any claims available to him against N&W in Louisiana state court pursuant to the saving to suitors clause. N&W and Wooley cross-appealed.   The Fifth Circuit affirmed. The court determines that a nondiverse defendant was improperly joined, the improperly joined defendant’s citizenship may not be considered for purposes of diversity jurisdiction, and that defendant must be dismissed without prejudice. After determining that N&W had been improperly joined, the district court correctly considered only the citizenship of the properly joined State Court Petition defendants. As they were diverse from Wooley, removal based on diversity jurisdiction was permitted. View "Wooley v. N&W Marine Towing" on Justia Law