Justia Admiralty & Maritime Law Opinion Summaries

In April 2006, an oil tanker owned or operated by Ernst Jacob GmbH & Co. KG and insured by Shipowners Insurance & Guaranty Company, Ltd. ran aground off the coast of Puerto Rico. Although no oil was spilled, the response efforts to free the vessel and prevent a potential spill caused significant damage to coral reefs. The United States, acting through NOAA and in coordination with Puerto Rico’s Department of Natural and Environmental Resources, undertook restoration and assessment of the damaged natural resources. After unsuccessful attempts to secure payment from the responsible parties and their insurers, NOAA sought compensation from the Oil Spill Liability Trust Fund, which paid out restoration and assessment costs. Subsequently, the United States filed suit against the vessel’s owner and insurer to recover both compensated and uncompensated damages for injury to natural resources under the Oil Pollution Act of 1990 (OPA).The United States District Court for the District of Puerto Rico bifurcated the case into liability and damages phases. Without allowing discovery, the District Court granted partial summary judgment to the United States on liability, finding that the Coast Guard’s Federal On-Scene Coordinator (FOSC) had determined the grounding posed a “substantial threat of a discharge of oil,” and that this determination was not arbitrary or capricious. The court applied a deferential standard of review to the FOSC’s decision and did not address whether the damaged natural resources were “managed or controlled” by the United States, as required by OPA.On appeal, the United States Court of Appeals for the First Circuit held that it had jurisdiction under 28 U.S.C. § 1292(a)(3) due to the presence of admiralty claims. The court vacated and reversed the District Court’s grant of summary judgment, holding that liability under OPA requires proof by a preponderance of the evidence, not merely deference to the FOSC’s determination, and remanded for further proceedings, including resolution of whether the United States “manages or controls” the natural resources at issue. View "US v. Ernst Jacob GmbH & Co. KG" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" 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

The case involves the Massachusetts Lobstermen's Association, Inc. (MALA) challenging a final rule issued by the National Marine Fisheries Service (NMFS) that seasonally bans vertical buoy lines used in lobster and Jonah crab trap fishing in certain federal waters off Massachusetts from February 1 to April 30 each year. The NMFS issued this rule to protect the endangered North Atlantic right whales from entanglement in these buoy lines during their foraging period.Previously, the U.S. District Court for the District of Massachusetts ruled in favor of MALA, holding that the final rule conflicted with a temporary statutory authorization for lobster and Jonah crab fishing contained in a rider to the Consolidated Appropriations Act of 2023. The district court found that the final rule did not fall within the exception provided in the rider, which allowed for actions to extend or make final an emergency rule that was in place on the date of the rider's enactment, December 29, 2022. The court concluded that the 2022 emergency rule was not "in place" on that date because it was not actively preventing fishing in the Wedge area at that time.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's decision. The appellate court held that the 2022 emergency rule was indeed "in place" on December 29, 2022, for the purposes of the rider's exception. The court reasoned that the emergency rule's findings and authority were still relevant and could serve as a basis for future regulatory actions, such as the final rule. Therefore, the final rule was lawful and enforceable under the exception provided in the rider. The case was remanded for further proceedings consistent with this opinion. View "Mass. Lobstermen's Ass'n, Inc. v. Nat'l Marine Fisheries Serv." on Justia Law

Regulations promulgated by the National Marine Fisheries Service require that commercial fishermen must, on occasion, be accompanied on their vessels by at-sea monitors to ensure accountability with respect to catch limits. The regulations require that the fishermen bear the costs of the at-sea monitors. Plaintiff, a New Hampshire fisherman subject to the industry funding requirement for the at-sea monitoring program, brought suit in federal district court claiming that the industry funding requirement violated several laws and was unconstitutional. Plaintiff was joined in the proceedings by a group of commercial fishermen also subject to the industry funding requirement. The district court granted summary judgment in favor of the government, concluding that the action was untimely filed. The First Circuit affirmed, holding that Plaintiff’s suit was not filed within the applicable statute of limitations. View "Goethel v. U.S. Department of Commerce" on Justia Law

Jamie Rogers, a seaman, was injured on a fishing vessel owned and operated by Block Island Fishing, Inc. Block Island made some “maintenance and cure” payments to Rogers. Block Island then brought this suit against Rogers to dispute the duration and amount of maintenance and cure payments that it owed. Block Island filed a motion for summary judgment. The district court found that November 18, 2014 was the date on which Block Island’s obligations ended and reserved for a jury to determine the exact sum that Block Island owed Rogers for his living expenses. The court then ruled that Block Island had overpaid Rogers and that Block Island could offset the sum of overpayment against any damages award that Rogers might win at trial. The First Circuit affirmed in part and vacated and remanded in part, holding (1) the district court erred by sua sponte replacing Block Island’s proposed date of July 31, 2014 with its own date without giving Rogers sufficient notice of opportunity to make his case against the new date; and (2) Block Island may offset any overpayment against Rogers’ potential damages award but may not sue for the sum in an independent action. View "Block Island Fishing, Inc. v. Rogers" on Justia Law

Plaintiff, a former professional sailor, was an employee of Defendant, which owed a sailing vessel and motor support vessel. Plaintiff was injured during his employment. Plaintiff later invoked admiralty jurisdiction and sued Defendant in federal district court alleging negligence under the Jones Act and unseaworthiness under general maritime law. The district court awarded Plaintiff $1,460,458 in damages for loss of earnings and loss of future earning capacity and for pain, suffering, and mental anguish. The court subsequently granted Plaintiff’s motion to add prejudgment interest to the damages award. Defendant appealed, arguing that the damages award was excessive and that the prejudgment interest increment was inappropriate. The First Circuit (1) affirmed the award of damages, holding that the award was not excessive; and (2) affirmed in part and reversed in part the interest award, holding that the district court committed reversible error in failing to follow Borges v. Our Lady of the Sea Corp. in awarding prejudgment interest. View "Nevor v. Moneypenny Holdings, LLC" on Justia Law