Tandon v. Captain's Cove Marina of Bridgeport, Inc., 752 F.3d 239

On May 28, 2010, owners of the recreational powerboat Up and Over (Tandon and Doohan) and their guests visited Captain’s Cove Marina in Bridgeport, CT; a physical altercation occurred on and around a floating South Dock, and Frank Genna suffered severe injuries after being knocked into the water.
Genna and his wife sued the marina and related parties in Connecticut state court; the marina filed third-party claims seeking contribution/indemnity from Tandon and Doohan and other Up and Over passengers.
Tandon and Doohan filed a federal petition for limitation of liability (Limitation of Liability Act), triggering a stay of state proceedings and a limitation proceeding in federal district court.
Several claimants filed claims in the limitation action; Ulbrick moved to dismiss the federal petition for lack of subject-matter jurisdiction under Fed. R. Civ. P. 12(b)(1).
The district court dismissed, holding admiralty jurisdiction was lacking under the Grubart test (location and connection tests); the Second Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal admiralty jurisdiction extends to torts from an on-/around-dock fistfight and thus supports a Limitation Act petition	The fight occurred partly in navigable water and followed boat conduct; admiralty jurisdiction therefore applies and limitation is available	The incident is a recreational fistfight on a permanent dock and does not have a potentially disruptive effect on maritime commerce, so admiralty jurisdiction is absent	Held: No admiralty jurisdiction; petition dismissed (location assumed arguendo, but connection test fails)

Executive Jet Aviation, Inc. v. City of Cleveland, 409 U.S. 249 (1972) (location alone insufficient; requires significant relationship to maritime activity)
Foremost Ins. Co. v. Richardson, 457 U.S. 668 (1982) (pleasure-boat collision in navigable water satisfied connection test due to potential effect on commerce)
Sisson v. Ruby, 497 U.S. 358 (1990) (fire on a docked vessel can potentially disrupt maritime commerce; two-part connection inquiry)
Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., 513 U.S. 527 (1995) (location and two-part connection test for admiralty tort jurisdiction)
Stewart v. Dutra Constr. Co., 543 U.S. 481 (2005) (permanently moored structure is not a "vessel")
Victory Carriers, Inc. v. Law, 404 U.S. 202 (1971) (historical scope of admiralty tort jurisdiction tied to locality; reserve shoreward matters for state courts)