In Offshore of Palm Beaches, Inc. v. Lynch, No. 13-11092 (11th Cir. Feb. 3, 2014), Offshore appealed the district court's order permitting a lone claimant to pursue personal injury claims in state court after Offshore had invoked the Limitation of Liability Act (Limitation Act), 46 U.S.C. sec. 30501. The court concluded that the district court did not abuse its considerable discretion in determining that the claimant could proceed first in state court with her tort claim before the district court adjudicated the boat owner's efforts to limit its liability to the value of the vessel. Accordingly, the court affirmed the judgment of the district court.
While the holding of the case is not of itself earth-shattering, the case provides an excellent summary of appellate jurisdiction over admiralty matters involving injunctions. If you or your client are considering whether an admiralty matter is appealable, this decision may be of importance to you.
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