Chem One, Ltd. v. M/V Rickmers Genoa, 660 F.3d 626

Casualty occurred March 8, 2005 when M/V Rickmers Genoa collided with M/V Sun Cross in the Yellow Sea, causing flooding, an explosion, a fire, and loss of cargo and a crewmember.
Cargo interests filed four admiralty actions in SDNY seeking damages for cargo losses and related salvages against Rickmers Genoa, Rickmers Interests, and ESM Group/ESMT among others.
ESM Group allegedly formed ESM Tianjin (ESMT) to manufacture SS-89 magnesium desulphurization reagent; ESM Group controlled production, supply chains, MSDS, and shipments to ESMT.
SS-89 was shipped aboard Rickmers Genoa; ESMT contracted Pudong Trans USA to transport SS-89; Pudong then arranged shipment to U.S. consignee, with Rickmers ultimately carrying the cargo.
District Court decisions (2009 and 2010) dismissed some direct and third-party claims against ESM Group but allowed liability theories for agency/veil piercing to proceed; later, all remaining ESMT-related claims were dismissed, ending liability against ESM Group and ESMT.
The ESM Parties moved to dismiss the interlocutory appeals as premature or, alternatively, to consolidate; the Second Circuit denied dismissal and granted consolidation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeals fall within interlocutory admiralty jurisdiction under 28 U.S.C. 1292(a)(3).	ESM contends jurisdiction lacks because not all claims against all parties resolved.	Rickmers/Chem One contend district court resolved liability against ESM Group/ESMT, enabling appeal.	Yes; jurisdiction exists because liability against ESM Parties was resolved and remaining claims were independent.
Whether consolidation of the multiple appeals was appropriate.	Consolidation would promote efficiency given the same underlying litigation.	Consolidation unnecessary or prejudicial due to different parties/cases.	Consolidation granted; appeals arising from the same multi-party litigation were efficiently consolidated.

Becker v. Poling Transportation Co., 356 F.3d 381 (2d Cir. 2006) (interlocutory appeal possible where liability determined even if others remain pending)
Thypin Steel Co. v. Asoma Corp., 215 F.3d 273 (2d Cir. 2000) (limits of 1292(a)(3) interpretation; allowing interlocutory review when merits decided)
In re Compl. of PMD Enter., Inc., 301 F.3d 147 (3d Cir. 2002) (admiralty interlocutory appeals permit review when rights/liabilities between some parties are decided)
Barbarino v. Stanhope S.S. Co., 151 F.2d 553 (2d Cir. 1945) (early precedent recognizing appealability when rights determined)
Wills Lines Inc. v. M/V Le Moyne D'Iberville, 227 F.2d 509 (2d Cir. 1955) (illustrative admiralty interlocutory review principles)