Justia Admiralty & Maritime Law Opinion Summaries

A volunteer firefighter with a fire district in New York suffered a serious foot injury while aboard the district’s firefighting vessel responding to a reported boat fire on the Hudson River. He was injured when he tried to prevent a collision between his vessel and a police boat. After the accident, he received compensation under New York’s Volunteer Firefighters’ Benefit Law, which provides workers’ compensation-like benefits for volunteers injured in the line of duty. Despite receiving these benefits, he filed claims in federal court against the fire district, alleging negligence and unseaworthiness under federal maritime law.The United States District Court for the Southern District of New York granted summary judgment to the fire district, finding that the firefighter was not entitled to bring claims under the Jones Act or under the Supreme Court’s precedent in Seas Shipping Co. v. Sieracki, and that the exclusive remedy provision of New York’s Volunteer Firefighters’ Benefit Law barred his general maritime law negligence claim. The firefighter appealed, contesting the denial of his Sieracki unseaworthiness and general maritime negligence claims.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court erred in concluding, as a matter of law, that the firefighter was not entitled to the warranty of seaworthiness extended to so-called "Sieracki seamen." It also concluded that New York’s exclusive remedy provision could not bar his federal negligence claim under general maritime law, given the significant federal interest in uniform maritime remedies. The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings to determine whether the firefighter met the requirements for Sieracki seaman status and to allow his general maritime negligence claim to proceed. View "In re Complaint of Verplanck Fire District" on Justia Law

A resident of Puerto Rico suffered work-related injuries in 1994, resulting in permanent total disability. His employer and its insurance carrier were ordered to provide medical care under Section 7 of the Longshore and Harbor Workers’ Compensation Act, as extended by the Defense Base Act. In 2019, a Puerto Rico-licensed physician recommended medical cannabis-infused edibles to treat the petitioner’s chronic pain. The petitioner sought reimbursement for these products from the employer’s insurance carrier, which denied the request.The petitioner then asked the United States Department of Labor’s Office of Administrative Law Judges to order reimbursement, arguing that medical cannabis was a reasonable and necessary treatment. The Administrative Law Judge denied the request, finding that marijuana’s classification as a Schedule I substance under the Controlled Substances Act (CSA) meant it could not have an accepted medical use under federal law. On appeal, the Department of Labor Benefits Review Board affirmed this decision by a 2-1 vote, agreeing that reimbursement was barred by the CSA and rejecting arguments that recent federal appropriations riders or executive actions altered the federal legal status of marijuana.On further appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court held that because marijuana remains a Schedule I substance under the CSA, it cannot be considered a reasonable and necessary medical expense for purposes of reimbursement under the Longshore and Harbor Workers’ Compensation Act. The court found that neither appropriations riders nor recent executive or legislative actions had changed marijuana’s federal classification or its legal status under the Act. Therefore, the court denied the petition for review. View "Garcia v. Department of Labor" on Justia Law

Nearly a million barrels of crude oil owned by a U.S. company were seized from a vessel in Venezuelan waters by Venezuelan authorities under threat of force. The oil was insured under a marine cargo reinsurance policy that covered losses arising from war-related risks, including “insurrection.” The insured company claimed that the political turmoil in Venezuela, including the contested presidency and violent suppression of opposition, constituted an insurrection as defined by the policy. The reinsurers denied coverage, arguing that the events did not meet the policy’s definition of insurrection, leading to litigation.The United States District Court for the Southern District of New York reviewed cross-motions for summary judgment. The court found the term “insurrection” in the policy to be ambiguous and, applying New York law and the doctrine of contra proferentem, construed the ambiguity in favor of the insured. The court held that the Maduro regime’s actions constituted an insurrection within the meaning of the policy. The case proceeded to trial on causation and damages, where the jury found in favor of the insured on most issues, awarding over $54 million in damages plus interest.On appeal, the United States Court of Appeals for the Second Circuit considered challenges to the district court’s summary judgment ruling, judicial notice orders, and jury instructions on causation. The Second Circuit held that the district court did not err or abuse its discretion in any of the challenged rulings. It affirmed that the policy’s “arising from” language required only but-for causation, not proximate causation. The court affirmed the district court’s judgment in all respects, upholding the award to the insured. View "CITGO Petroleum Corp. v. Ascot Underwriting Ltd." on Justia Law

Ed Seganti, the owner of a 2018 Cobia motorboat, was involved in a boating collision near Goose Creek in Nassau County on May 29, 2022. Nancy Skolnik, a passenger on another boat, was injured in the accident. On September 22, 2022, Skolnik’s attorney sent Seganti a letter notifying him of her intent to pursue a personal injury claim arising from the collision. Nearly a year later, Skolnik filed suit in New York State Supreme Court against Seganti and the other boat’s operator. On November 1, 2023, Seganti filed a petition in the U.S. District Court for the Eastern District of New York seeking to limit his liability under the Limitation of Liability Act.The U.S. District Court for the Eastern District of New York determined that Seganti’s petition was untimely because it was filed more than six months after he received written notice of Skolnik’s claim. The court held that this untimeliness deprived it of subject matter jurisdiction and dismissed the action on that basis.The United States Court of Appeals for the Second Circuit reviewed the district court’s decision. The Second Circuit held that the six-month time limit in 46 U.S.C. § 30529(a) is a non-jurisdictional claim-processing rule, not a restriction on subject matter jurisdiction. However, because Seganti’s petition was untimely, the appellate court concluded that the petition failed to state a claim upon which relief could be granted. The Second Circuit modified the district court’s judgment to reflect dismissal under Federal Rule of Civil Procedure 12(b)(6) with prejudice, and affirmed the judgment as modified. The main holding is that the six-month deadline in § 30529(a) is not jurisdictional, but failure to comply with it requires dismissal for failure to state a claim. View "In the Matter of the Complaint of Ed Seganti" on Justia Law

Ficarra filed suit against petitioner, asserting claims of negligence stemming from a tort involving a vessel on navigable waters. More specifically, the case involves a diving accident off a recreational vessel anchored in shallow but navigable lake waters. The district court concluded that there was no admiralty jurisdiction here and reasoned that a recreational injury occurring on a recreational vessel anchored in a shallow recreational bay of navigable waters could not disrupt maritime commerce and did not bear a sufficient relationship to traditional maritime activity. Although the court concluded that the district court correctly articulated the Supreme Court’s modern test for admiralty tort jurisdiction, the court respectfully disagreed with its conclusion that jurisdiction is lacking here. The Supreme Court instructed the court that, “ordinarily,” “every tort involving a vessel on navigable waters falls within the scope of admiralty jurisdiction.” Therefore, petitioner's appeal of the dismissal of his petition seeking exoneration from or limitation of liability was proper, and the district court has jurisdiction over that petition. The court reversed and remanded. View "In Re Petition of Bruce Germain" on Justia Law