Articles Posted in Admiralty & Maritime Law

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A recreational boating accident killed four adults. The boat had been rented from Aramark Sports and Entertainment Services, LLC. Because the accident occurred on navigable waters, the case fell within federal admiralty jurisdiction. Anticipating that it would be sued for damages, Aramark filed in the United States District Court for the District of Utah a petition under the Limitation of Liability Act, which permitted a boat owner to obtain a ruling exonerating it or limiting its liability based on the capacity or value of the boat and freight. The district court denied the petition, leaving for further proceedings the issues of gross negligence, comparative fault, and the amount of damages. Aramark appealed the denial. After review, the Tenth Circuit held the district court erred in its application of admiralty principles of duty and remanded for further proceedings. View "In re: Aramark Sports" on Justia Law

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The Miss Dixie was a cargo line boat operated by defendant-appellant Jantran, Inc., a company involved in maritime transportation on the Verdigris River in Oklahoma. The Miss Dixie struck and extensively damaged a lock maintained by the Army Corps of Engineers. After repairing the lock, the Corps sued Jantran for the costs of repair. The district court dismissed the Corps' suit, concluding that federal law did not allow the Corps to seek in personam damages directly from the owners of a vessel that damages a structure on navigable waters. As the court found, the applicable statute, the Rivers and Harbors Act, only allowed in rem claims against the vessel that caused the damage. After review, the Tenth Circuit agreed with the district court that the Act did not authorize in personam actions against the owners of the vessel. The Act only allowed the Corps to proceed in rem against the vessel itself. The Court therefore affirmed the district court's ruling. View "United States v. Jantran" on Justia Law