United States Second Circuit

In a petition for exoneration from or limitation of liability under the Limitation of Liability Act of 1851, 46 U.S.C. sections 30501-12, the District Court's dismissal for lack of subject matter jurisdiction is reversed where, applying a recent Supreme Court multi-part test for admiralty jurisdiction, a recreational injury occurring on a recreational vessel anchored in a shallow recreational bay of navigable waters could disrupt maritime commerce and did bear a sufficient relationship to traditional maritime activity.

Appellate Information

• Published 2016/06/01

Judges

• KATZMANN

Court

• United States Second Circuit

Counsel