Justia Admiralty & Maritime Law Opinion Summaries

AdvanFort Company, a maritime security firm based in Virginia, deployed a vessel, the Seaman Guard Virginia, for anti-piracy services in the Red Sea. In October 2013, the vessel docked at the Jeddah Shipyard in Saudi Arabia for repairs by Zamil Offshore Services Company. During the repairs, a fire broke out, which AdvanFort attributed to Zamil's personnel. AdvanFort sued Zamil and the Saudi Ports Authority in a Saudi court in 2014, but the court dismissed AdvanFort's claims and awarded partial damages to Zamil on its countersuit. In 2022, Zamil moved the vessel to a storage yard, claiming it was at risk of sinking, and later informed AdvanFort that it would dispose of the vessel if not retrieved.AdvanFort filed a complaint in the Eastern District of Virginia in July 2023, alleging conversion, breach of bailment, negligence, and gross negligence against Zamil and the Ports Authority. Zamil moved to dismiss the complaint on the grounds of forum non conveniens and lack of personal jurisdiction, arguing that Saudi courts were a more appropriate forum. The Ports Authority did not appear, leading to a default entry against it.The United States District Court for the Eastern District of Virginia dismissed AdvanFort's complaint on the basis of forum non conveniens, finding that Saudi courts were available, adequate, and more convenient for the litigation. The court noted that the relevant events and evidence were located in Saudi Arabia and that the Saudi courts had jurisdiction over both defendants.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court held that the district court did not abuse its discretion in determining that Saudi Arabia was a more convenient forum and that the Saudi courts were both available and adequate for adjudicating AdvanFort's claims. The court also found no error in the district court's denial of limited discovery on forum non conveniens issues. View "AdvanFort Co. v. Zamil Offshore Services Co." on Justia Law

A tragic boat accident occurred when Edward Barnett, while navigating a coastal river, crashed into a dike, resulting in his and his coworker's deaths. Penny Jo Barnett, his widow, sued the Coast Guard, alleging that their failure to maintain navigational aids caused the crash. She claimed the Coast Guard did not properly maintain the lights that were supposed to warn mariners of the dike’s presence.The United States District Court for the District of South Carolina ruled in favor of the Coast Guard after a bench trial. The court found that the Coast Guard was immune from the allegations under the discretionary function exception to the Suits in Admiralty Act (SIAA). The court also held that the failure to repair one non-working light on the dike did not breach the Coast Guard’s duty to repair aids to navigation in a reasonable time. Additionally, the court concluded that Edward Barnett’s own actions were the sole proximate cause of the accident.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the discretionary function exception applied to the Coast Guard’s decisions regarding the brightness, flash sequence, and background lighting of the navigational aids. The court found no statute, regulation, or policy requiring the Coast Guard to take specific actions to alter or improve these aids. The court also upheld the district court’s finding that Edward Barnett’s actions, including exiting the navigable channel, not using a chart plotter, and traveling at high speed at night, were the sole proximate cause of the crash. Thus, the Coast Guard did not breach any duty under maritime negligence theory, nor did it cause the crash. View "Barnett v. United States" on Justia Law

Plaintiffs, a group of charter-boat operators and trade associations in Maryland, sued the Atlantic States Marine Fisheries Commission to enjoin the Commission’s striped-bass plan. The Commission, formed in 1942, recommends fishery management plans to its member states. Plaintiffs argued that the plan, which included a one-fish limit for charter boats, would significantly harm their businesses. They sought an injunction to prevent the implementation of the plan.The United States District Court for the District of Maryland denied Plaintiffs’ motion for a preliminary injunction. The court found that Plaintiffs likely lacked standing because they were regulated by Maryland, not the Commission. The court noted that even if the Commission’s plan were enjoined, it was unlikely that Maryland would rescind its own regulations, which were stricter than the Commission’s recommendations. The court also found that Plaintiffs did not plausibly state a claim for relief under 42 U.S.C. § 1983, as the Commission is not a “person” under the statute and does not act under “color of state law.”The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that Plaintiffs lacked standing to sue. The court held that Plaintiffs failed to plausibly allege that Maryland would likely rescind its regulations if the Commission’s plan were enjoined. The court emphasized that Maryland voluntarily adopted the regulations and had the authority to impose stricter measures than those recommended by the Commission. As a result, the court vacated the district court’s order denying the preliminary injunction and remanded the case with instructions to dismiss for lack of jurisdiction. View "Delmarva Fisheries Association, Inc. v. Atlantic States Marine Fisheries Commission" on Justia Law

These appeals stemmed from ICI's breach of numerous contracts. Flame and Glory Wealth sought a writ of maritime attachment under Supplemental Rule B of the Federal Rules of Civil Procedure to attach the vessel M/V CAPE VIEWER when it docked in Norfolk, Virginia. Freight Bulk is the registered owner of the vessel, but Flame and Glory Wealth asserted that Freight Bulk was the alter ego of ICI, and that ICI had fraudulently conveyed its assets to Freight Bulk in order to evade its creditors. The district court awarded judgment to Flame and Glory Wealth, ordered the sale of the M/V CAPE VIEWER, and confirmed the distribution of the sale proceeds to Flame and Glory Wealth. Freight Bulk appealed. The court rejected Freight Bulk's arguments regarding subject matter jurisdiction, Glory Wealth's judgment against ICI, discovery sanctions, and sufficiency of the evidence. Because the court found no merit in Freight Bulk's claims, the court affirmed the judgment. View "FLAME S.A. v. Freight Bulk Pte. Ltd." on Justia Law