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In re Mission Bay Jet Sports, LLC

Practice Area: Admiralty and maritime

Outcome: Appeal Granted, Reversed and Remanded

Description: Plaintiffs-in-Limitation brought an action under the Limitation of Liability Act, 46 U.S.C. 30501 et seq. for exoneration from or limitation of liability regarding an accident that occurred involving a personal watercraft on Mission Bay in San Diego. Two claimants appeared to move to dismiss the action for lack of admiralty jurisdiction. The district court granted the motion. Plaintiffs-in-Limitation appealed. On appeal, the Ninth Circuit determined that the test for admiralty jurisdiction as set forth by the U.S. Supreme Court in various cases was satisfied, despite the fact that the accident had occurred in a part of Mission Bay that was reserved exclusively for use by personal watercraft. First, the Court found that the waters where the accident occurred were subject to tidal influences and therefore were navigable. Second, it found that the accident involved by a vessel in navigable waters to a passenger, and therefore presented the requisite potential to disrupt maritime commerce. Finally, it found that the activity giving rise to the accident was the operation of a vessel in navigable waters, and therefore presented the requisite substantial relationship to traditional maritime activity. Since the Court found that the accident met all of the requirements for admiralty jurisdiction, the Court granted the appeal, reversed the decision of the district court, and remanded the case for further proceedings.

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