What are the Bounds of U.S. District Courts' Admiralty Tort Jurisdiction?
In a recent decision, Tandon v. Captain's Cove Marina of Bridgeport, Inc., 2014 U.S. App. LEXIS 9265 (2d Cir. Conn. May 19, 2014), the Second Circuit Court of Appeals clarified the extent of admiralty tort jurisdiction, holding that tort claims arising from a fistfight on and around a permanent dock do not fall within the District Court's admiralty jurisdiction. In reaching its conclusion, the Second Circuit applied the test for admiralty tort jurisdiction established by the U.S. Supreme Court in Jerome B. Grubart v. Great Lakes Dredge & Dock Co., 513 U.S. 527 (1995). The Grubart test provides that admiralty jurisdiction can be exercised over a tort where both the location test and the connection test are satisfied. The location test requires the tort to have occurred on navigable water or to have been caused by a vessel on navigable water. The connection test requires that (i) the general type of incident has a potentially disruptive effect on maritime commerce; and (ii) the general character of the activity at issue must have a substantial relationship with maritime commerce.
In Tandon, a fistfight broke out on and around a permanent dock surrounded by navigable water, where one individual was physically held underwater to the point of asphyxia. This individual commenced an action in Connecticut state court against, inter alia, the owners of the powerboat Up and Down and their passengers, who were involved in the altercation. Thereafter, the Owners of the Up and Down filed a petition for exoneration from or limitation of liability in the United States District Court for the District of Connecticut. This petition is a form of relief which is specific to admiralty and maritime cases. 46 U.S.C. § 30505(a) provides that "the liability of an owner of a vessel for any claim, debt or liability [covered by the Act] shall not exceed the value of the vessel and pending freight." Based on this statute, an owner of a vessel can seek to limit its liability by commencing a civil action in a U.S. District Court. 46 U.S.C. § 30511(a). However, District Courts are only found to have admiralty jurisdiction to address a petition for limitation where the District Court already has admiralty jurisdiction over the underlying claims which the vessel owner seeks to limit.
Assessing the tort claims at issue, the District Court held that it did not have admiralty jurisdiction over the case, and dismissed the owners' petition for lack of subject matter jurisdiction. The Second Circuit reviewed the tort claims in the context of the Grubart test, and upheld the District Court's decision. First, considering the location test, the Second Circuit recognized that the fistfight occurred both on the floating dock, which was connected to the harbor floor, and in the surrounding water. The Court nonetheless declined to decide the "difficult question" of whether the location test was satisfied, holding that the connection test was not met. Specifically, the incident at issue – a physical altercation between visitors on and around a permanent dock – does not pose a threat to maritime commerce, and does not obstruct the passage of commercial vessels along navigable waterways. Accordingly, the Second Circuit held that the District Court properly declined to exercise admiralty jurisdiction over this matter, and upheld the dismissal of the petition for lack of subject matter jurisdiction.
To read a copy of the Second Circuit Court of Appeals' Decision in Tandon v. Captain's Cove Marina of Bridgeport, Inc., case number 13-461, click here.
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