Justia Admiralty & Maritime Law Opinion Summaries

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The case involves a dispute over the legality of an agreement between River 1, LLC, an American company, and Viking USA LLC, a subsidiary of a Swiss company, under federal maritime law. The United States Maritime Administration (MARAD) had confirmed the legality of the agreement as a "time charter" under 46 U.S.C. § 56101(a)(i). However, American Cruise Lines argued that the agreement should be construed as a "bareboat" charter which is not covered under the standing blanket approval of MARAD, and thus, grants a foreign company impermissible control of an American vessel.The United States Court of Appeals for the Second Circuit affirmed MARAD's decision. It found that the agreement didn't grant Viking exclusive possession and control of the cruise ship in a way that blackletter maritime law recognizes as sufficient to create a bareboat charter. It noted that the ship's crew was provided by River 1, the vessel master was overseen by River 1, and River 1 bore primary responsibility for the ship’s day-to-day maintenance and care. Viking's ability to set the itinerary was consistent with the maritime law definition of a time charter.The court also rejected American Cruise Lines' allegations that MARAD failed to follow the notice and comment provisions applicable to this case. It concluded that MARAD fully complied with the new procedural requirements imposed by the National Defense Authorization Act of 2021. View "American Cruise Lines v. United States of America" on Justia Law

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This case involves a maritime personal injury claim brought by Plaintiff Shanon Roy Santee against his employer, Oceaneering International, Inc., and two other companies, Transocean Offshore Deepwater Drilling, Inc. and Chevron USA, Inc. Santee was a remote-operated vehicle (ROV) technician working on a drillship, the Deepwater Conqueror. He sustained an injury while replacing a part on one of the ROVs and subsequently sued the three companies under the Jones Act, general maritime law, and the Saving to Suitors Clause.The defendants removed the case to the Southern District of Texas, arguing that the federal court had jurisdiction under the Outer Continental Shelf Lands Act (OCSLA). Santee moved to remand the case to state court, arguing he was a "seaman" under the Jones Act. The district court denied the motion and granted summary judgment in favor of the defendants.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The appellate court agreed that Santee was not a seaman under the Jones Act, so his Jones Act claims were fraudulently pleaded. The court also found that the district court had original jurisdiction under the OCSLA because the drillship was on the Outer Continental Shelf at the time of Santee's injury. Consequently, Santee's only remedy was under the Longshore and Harbor Workers' Compensation Act.The court also found no error in the district court's decision to grant summary judgment in favor of the defendants on Santee's negligence and unseaworthiness claims. It concluded that the defendants did not breach their duties to Santee, and Santee failed to show that additional discovery would have created a genuine issue of material fact. View "Santee v. Oceaneering Intl." on Justia Law

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In this case, the United States Court of Appeals for the District of Columbia Circuit examined a dispute over Final Amendment 53 to the Fishery Management Plan for the Reef Fish Resources of the Gulf of Mexico. Commercial fishers challenged the amendment, which modified the allocation of red grouper between commercial and recreational sectors, for relying on inconsistent economic analyses and failing to comply with the Magnuson-Stevens Fishery Conservation and Management Act.The commercial fishers argued that the Final Amendment 53 arbitrarily relied on an economic analysis that the Fisheries Service had previously rejected and that it lacked the required catch limits and accountability measures. They also claimed that the amendment violated National Standards 4 and 9 of the Act.The court agreed with the commercial fishers in part, affirming that the Fisheries Service had failed to adequately explain its reliance on the disputed economic analysis and that further analysis was needed to determine how this influenced the application of National Standards 4 and 9. However, it also affirmed that Final Amendment 53 complied with the Act's requirement to establish a mechanism for specifying annual catch limits.As a result, the court affirmed in part and reversed in part the grant of summary judgment to the Secretary of Commerce. It remanded the case, without vacating the Final Rule implementing Final Amendment 53, so the Fisheries Service could further explain its economic methodology and the implications for National Standards 4 and 9. View "A.P. Bell Fish Company, Inc. v. Raimondo" on Justia Law

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In a maritime insurance dispute between Great Lakes Insurance, a German company, and Raiders Retreat Realty, a Pennsylvania company, the Supreme Court of the United States ruled that choice-of-law provisions in maritime contracts are presumptively enforceable under federal maritime law, with certain narrow exceptions not applicable in this case.The dispute originated when Raiders Retreat Realty's boat ran aground, and Great Lakes Insurance denied coverage, alleging that Raiders breached the insurance contract by failing to maintain the boat’s fire-suppression system. The insurance contract contained a choice-of-law provision that selected New York law to govern future disputes. Raiders argued that Pennsylvania law, not New York law, should apply. The District Court ruled in favor of Great Lakes, finding that the choice-of-law provision was presumptively valid and enforceable under federal maritime law. The Third Circuit Court of Appeals vacated this decision, holding that choice-of-law provisions must yield to the strong public policy of the state where the suit is brought.The Supreme Court reversed the Third Circuit's decision, emphasizing the importance of uniformity and predictability in maritime law. The Court concluded that choice-of-law provisions allow maritime actors to avoid later disputes and the ensuing litigation and costs, thus promoting maritime commerce. Therefore, such provisions are presumptively enforceable under federal maritime law. The Court further clarified that exceptions to this rule exist but are narrow, and none of them applied in this case. View "Great Lakes Insurance SE v. Raiders Retreat Realty Co." on Justia Law

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In this case heard by the United States Court of Appeals for the Ninth Circuit, the plaintiff's wife died during a scuba and snorkeling tour from Lahaina Harbor to Molokini Crater, an atoll off the coast of Maui, Hawaii. Before the tour, the plaintiff and his wife each signed a waiver document releasing their rights to sue the defendants. The plaintiff's claims were based on gross negligence and simple negligence. The defendants argued that the waiver and release were an affirmative defense to the claims based on simple negligence. However, the district court struck the defense, stating that the liability waivers were void under 46 U.S.C. § 30527(a), which prohibits certain liability waivers for vessels transporting passengers between ports in the United States or between a port in the United States and a port in a foreign country.The Ninth Circuit reversed the district court's order and held that the term "between ports in the United States" in 46 U.S.C. § 30527(a) refers to transportation between at least two separate ports in the United States. Therefore, the statute does not apply to vessels that transport passengers away from and back to a single port without stopping at any other port. The Court remanded the case for further proceedings. View "EHART V. LAHAINA DIVERS, INC." on Justia Law

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This case involves a lawsuit against the United States for allegations of negligence in a search-and-rescue mission by the U.S. Coast Guard. The plaintiffs, the estate of Aaron Greenberg (who drowned in a boating accident), Adrian Avena (who survived the accident), and AA Commercial, LLC, claimed that the Coast Guard was negligent in its response to the distress signal from their capsized vessel. They argued that the Coast Guard broadcasted incorrect information about the vessel in distress and did not deploy the closest helicopter for the rescue mission.The United States Court of Appeals for the Third Circuit affirmed the lower court's dismissal of the case, stating that the United States was immune from such a suit. According to the court, the plaintiffs failed to show how the Coast Guard's alleged negligence "increased the risk of physical harm" to Greenberg. The court noted that under the "Good Samaritan" doctrine, the Coast Guard would only be liable if its actions increased the risk of harm or if harm was suffered because of the plaintiffs' reliance on the Coast Guard. In this case, the court found that even if the Coast Guard had done nothing, the outcome would have been the same, thus the Coast Guard did not increase the risk of harm to Greenberg.Furthermore, the court denied the plaintiffs' motion for leave to amend their complaint, stating it would be futile as they had not identified any set of facts that could demonstrate how the Coast Guard's actions increased the risk of physical harm to Greenberg. View "Avena v. Avena" on Justia Law

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In a personal injury lawsuit, Carelyn Fylling sued Royal Caribbean Cruises for negligence after she tripped, fell, and hit her head while entering a deck on one of their cruise ships. The case was tried before a jury in the United States District Court for the Southern District of Florida. During the trial, the court became aware that one of the jurors had a niece who worked for Royal Caribbean. Despite this potential conflict of interest, the court did not remove or question this juror about any potential bias, and allowed her to participate in deliberations. The jury found Royal Caribbean negligent, but also found Fylling comparative-negligent, reducing her recovery by ninety percent. Fylling appealed to the United States Court of Appeals for the Eleventh Circuit, arguing that the lower court abused its discretion by not investigating the potential bias of the juror related to an employee of the defendant.The Eleventh Circuit agreed with Fylling. The court held that the district court abused its discretion by not investigating whether the juror could impartially discharge her responsibilities once it became aware of her potential bias. The court explained that when a district court becomes aware of potential juror bias, it is required to develop the factual circumstances sufficiently to make an informed judgment as to whether bias exists. A district court's obligation to protect the right to an impartial jury does not end when the jury is impaneled and sworn. The Eleventh Circuit therefore reversed the judgment and remanded the case for a new trial. View "Fylling v. Royal Carribean Cruises, Ltd." on Justia Law

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In a dispute between Conti 11 Container Schiffarts-GMBH & Co. KG M.S. and MSC Mediterranean Shipping Company S.A., the United States Court of Appeals for the Fifth Circuit found that the District Court for the Eastern District of Louisiana lacked personal jurisdiction over the case and reversed the district court's decision. The dispute arose from an incident where three chemical tanks exploded onboard a cargo vessel chartered by Conti to MSC, causing extensive damage and three deaths. After Conti won a $200 million award from a London arbitration panel, Conti sought to confirm the award in the Eastern District of Louisiana. MSC argued that the court lacked personal jurisdiction. The Fifth Circuit agreed with the district court’s assessment that when confirming an award under the New York Convention, a court should consider contacts related to the underlying dispute, not just those related to the arbitration itself. However, the Fifth Circuit disagreed with the district court's ruling that MSC waived its personal jurisdiction defense through its insurer’s issuance of a letter of understanding. The court also disagreed with the district court's finding that the loading of the tanks in New Orleans conferred specific personal jurisdiction over MSC, as this contact resulted from the actions of other parties not attributable to MSC. Therefore, the Fifth Circuit reversed the lower court's decision and remanded the case with instructions to dismiss it for lack of personal jurisdiction. View "Conti 11. Container Schiffarts-GMBH & Co. KG M.S. v. MSC Mediterranean Shipping Co. S.A." on Justia Law

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The United States Court of Appeals for the Ninth Circuit affirmed two defendants’ convictions for violating the Maritime Drug Law Enforcement Act (MDLEA), which prohibits the possession of a controlled substance with intent to distribute while on board a covered vessel. The defendants were arrested after their speedboat, which was carrying at least 1,000 kilograms of cocaine, was intercepted by the U.S. Coast Guard off the coast of Ecuador. The vessel carried no nationality flag, but both defendants verbally claimed Ecuadorian nationality for the vessel. The Ecuadorian government neither confirmed nor denied the nationality. The United States treated the vessel as stateless and exercised jurisdiction. The defendants challenged the government’s jurisdiction, arguing that the relevant provision of the MDLEA under which jurisdiction was exercised is unconstitutional because it conflicts with international law regarding when a vessel may be treated as stateless. The court held that the definition of “vessel without nationality” under the MDLEA does not conflict with international law, and thus affirmed the lower court’s denial of the defendants’ motion to dismiss the indictment. View "USA V. MARIN" on Justia Law

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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