First Circuit Affirms Judgment of Exoneration by Default in Limitation Case

On May 2, 2023 the United States Court of Appeals for the First Circuit affirmed the United States District Court for the District of Massachusetts’ Judgment of Exoneration by Default in favor of a fishing vessel owner for all claims arising out of a certain fishing trip ending in or around June of 2017. Olaf Aprans represented the vessel owner both in the trial court and on appeal.

A former deckhand filed a complaint for personal injuries in Massachusetts State Court, after which the vessel owner filed an action under the Limitation of Liability Act in the U.S. District Court for Massachusetts. The deckhand filed an answer, but failed to file a claim under Rule F of the Supplemental Admiralty Rules. The District Court accordingly entered Judgment of Exoneration by Default upon the motion we filed on behalf of our client.

On appeal, the claimant argued that an answer was sufficient to be a claim under Rule F and that even if it was not, he should have been granted leave to file a late claim. Claimant argued that the District Court should not have applied the “excusable neglect” standard when evaluating whether to grant such leave.

The First Circuit rejected Claimant’s arguments and held the District Court applied the correct standard. The First Circuit affirmed the judgment of the District Court, emphasizing both the trial court’s wide discretion and the need to maintain the efficient administration of the admiralty rules. The First Circuit additionally adopted the Eighth Circuit’s holding that filing a Claim is a standing prerequisite to filing an Answer.

See the filing of the Court’s decision, 05/02/2023.

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