In the matter of: Magnolia Fleet, LLC
2:16-cv-12297
E.D. La.Oct 19, 2017Background
- On Dec. 30, 2015 the M/V PINTAIL capsized while being operated by River Construction employees; one operator died and claimant Jeffrey Jenkins was injured. Petition for limitation of liability was filed by Magnolia Fleet (owner) and River Construction (operator).
- Jenkins (claimant) adopted a prior motion arguing River Construction is not an owner or owner pro hac vice of the PINTAIL and thus not entitled to limit liability; River Construction contends it is an owner pro hac vice.
- Petitioners moved to dismiss Jenkins’s punitive damages claim; Jenkins contends punitive damages are available if he is classified as a longshoreman (not as a seaman).
- Jenkins moved for summary judgment to preclude Petitioners from exoneration or limitation, arguing negligence, unseaworthiness, and privity/knowledge by Petitioners caused the accident.
- Factual dispute centers on the parties’ informal arrangement over use/control of the PINTAIL (shared use, keys under seat, no written agreement), who provided crew/training/maintenance, and prior engine repair/maintenance history.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether River Construction is an "owner" or owner pro hac vice entitled to limit liability | River Construction lacked the requisite dominion/control and was only an operator, so it cannot limit liability | River Construction exercised sufficient operational control, mans and navigates the vessel, and is an owner pro hac vice | Denied summary judgment — fact issue exists whether River Construction had requisite dominion; trial required |
| Whether Jenkins can recover punitive damages under general maritime law | If classified as a longshoreman, punitive damages are available because Petitioners acted recklessly (inadequate training, known engine problems) | Even if longshoreman, conduct did not rise to gross negligence/recklessness; maintenance performed recently and operators experienced | Denied summary judgment — reasonable juror could find conduct tantamount to gross negligence; trial required |
| Whether Petitioners are precluded from limitation/exoneration (privity/knowledge) | Petitioners had privity/knowledge of negligence and unseaworthiness (poor training, prior engine issues) so cannot limit liability | Disputes over adequacy of training and causation; Jenkins may have failed to report prior issues | Denied summary judgment — privity/knowledge, causation, and seaman status are factual issues for trial |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting)
- McBride v. Estis Well Serv., L.L.C., 768 F.3d 382 (seaman punitive damages limits under maritime law)
- Exxon Shipping Co. v. Baker, 554 U.S. 471 (purpose and standard for punitive damages)
- In re Am. Milling Co., Ltd., 409 F.3d 1005 (owner/charterer dominion/control analysis)
- Farrell Lines Inc. v. Jones, 530 F.2d 7 (two-step limitation/privity analysis)
- Guzman v. Pichirilo, 369 U.S. 698 (demise/bareboat charter and relinquishment of possession concept)