Kelley Mala v. Crown Bay Marina, 58 V.I. 691

Mala, a pro se U.S. Virgin Islands citizen, sued Crown Bay Marina after his boat exploded following a fueling incident.
The fueling pump allegedly malfunctioned; an attendant shut off the pump and provided cleaning supplies.
Mala filed a complaint in the Virgin Islands District Court asserting negligent training/supervision and negligent maintenance; he requested a jury trial.
The District Court identified the parties and dismissed others, struck Mala’s jury demand, but empaneled an advisory jury.
At trial a verdict of $460,000 for Mala was returned, but the court granted summary judgment for Crown Bay on the negligent-supervision claim and rejected the advisory verdict.
Mala appealed asserting pro se rights, denial of a jury trial, and improper adoption of magistrate recommendations; the Third Circuit affirmed the district court’s decisions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Pro se status attention duties of the court	Mala argues the court should have provided a pro se manual and extra assistance.	The court was under no obligation to provide general legal advice or hand-holding to pro se litigants.	No right to a pro se manual; court did not abuse discretion.
Right to jury trial and jurisdiction	District Court’s handling denied Mala a jury trial by misclassifying jurisdiction.	Court properly found admiralty (and lacked diversity); no jury right.	Mala lacked a jury-trial right; district court’s jurisdiction finding affirmed.
Advisory jury verdict and post-trial rulings	Advisory jury findings should have controlled the outcome.	Advisory jury findings are nonbinding and district court could reject them.	Court did not err in using an advisory jury or in rejecting its verdict; affirmed.
Diversity evidence and burden of proof	Mala contends Crown Bay was Florida-diverse; pro se status should aid interpretation.	Mala failed to prove Crown Bay’s Florida citizenship; not diverse.	Diversity not proven; no removal of jury-right or jurisdiction.
Magistrate recommendations and post-trial review	Court did not properly review magistrate’s recommendations.	Judges carefully explained reasons; proper review conducted.	No reversible error in adopting magistrate’s recommendations.

McKaskle v. Wiggins, 465 U.S. 168 (U.S. 1984) (no right to trial-court assistance as counsel; judges must remain neutral)
McNeil v. United States, 508 U.S. 106 (U.S. 1993) (no constitutional right to personal courtroom procedure guidance)
Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to represent oneself but not to receive court-provided legal chores)
Pliler v. Ford, 542 U.S. 225 (U.S. 2004) (no obligation to warn pro se litigants about consequences of procedural defaults)
Castro v. United States, 540 U.S. 375 (U.S. 2003) (need to inform pro se litigants when converting motions; notice is an exception to nonassistance rule)
Haines v. Kerner, 404 U.S. 519 (U.S. 1972) (liberally construe pro se pleadings; limited exceptions apply)
Houston v. Lack, 487 U.S. 266 (U.S. 1988) (prisoners’ notices of appeal treated as timely when delivered to prison authorities)
Gorman v. Cerasia, 2 F.3d 519 (3d Cir. 1993) (saves common-law remedies under saving-to-suitors clause in admiralty)