The case involved a dispute over a promissory note for the purchase of the vessel O/S Nordic Maiden, where defendants Kenyon, Clarke, and Rust deposited the first installment payment into a state court registry while suing plaintiff King in state court for contract reformation and damages, prompting King to file this federal admiralty action to foreclose on an alleged preferred ship mortgage after declaring default and acceleration. Defendants moved for summary judgment, arguing their deposit satisfied the payment obligation under the note. The court denied the motion, holding that no genuine issues of material fact existed and that the deposit did not constitute payment because it was not received by King, as required by the note's terms and the legal definition of payment under Washington law. The court reasoned that tender requires an offer to the creditor, which was absent here, and that the merits of the parallel state action were irrelevant to King's right to enforce the mortgage in admiralty.
This case concerned competing claims to the proceeds from the sale of the fishing vessel O/S Pacific Horizon. Bellingham National Bank sought foreclosure of its preferred ship mortgage recorded in 1983 after advancing funds for the vessel's purchase, while intervenor Peter Pan, Inc. asserted a preferred maritime lien for supplying a $16,000 purse seine net. The court granted summary judgment to the bank, ruling that Peter Pan held no maritime lien on the Pacific Horizon. The core reasoning was that the net had been furnished to a different vessel (the O/S Dolphin) in 1977, and its later transfer did not satisfy the requirements of 46 U.S.C. § 971 for creating a lien on the Pacific Horizon, as maritime liens are strictly construed and require direct furnishing to the vessel in question.
This admiralty case arose after a cargo of cement shipped under a bill of lading from Korea to Qatar was lost when the vessel sank. The bill of lading contained an exclusive forum-selection clause requiring all disputes to be resolved in Korean courts under Korean law. Plaintiffs sued in U.S. district court, attached another vessel owned by the defendant, and obtained a letter of undertaking to release it; the court initially dismissed the action based on the clause and later reconsidered whether it could retain the security to enforce a potential Qatari judgment. The court held that the clause was valid and enforceable, expressly excluding jurisdiction of any other country's courts—including for purposes of the attachment or undertaking—and affirmed dismissal of the security. It relied on Supreme Court and Ninth Circuit precedent treating such clauses as prima facie valid absent fraud or overreaching.
This case involved a plaintiff who filed an admiralty action in federal court to recover damages from a vessel collision at Dutch Harbor, Alaska. The parties reached a settlement agreement, but the defendant only partially paid the agreed amount. The court initially denied the plaintiff's motion for judgment on the unpaid balance, citing limits on admiralty courts' equitable powers to enforce private contracts. On reconsideration, the court granted the motion and entered judgment for the remaining sum plus interest. The reasoning was that although admiralty courts lack full equity powers, they may enforce a settlement agreement when the original claim was properly brought within admiralty jurisdiction, as such enforcement serves judicial economy and is subsidiary to the maritime dispute.
In Price v. Seattle-First National Bank, the plaintiff alleged that the defendant bank improperly seized and sold his vessel without judicial process or notice after it sank at its moorings, following his default on a preferred ship mortgage securing a loan; the bank had raised the vessel, found it nearly worthless, and sold it at auction for a fraction of the debt, which exceeded $169,000. Price moved for summary judgment to bar the bank from obtaining a deficiency judgment, arguing that the Ship Mortgage Act, 46 U.S.C. § 951, provides the exclusive foreclosure procedure. The court denied the motion, holding that while the Act supplies the exclusive judicial remedy in federal admiralty courts for preferred ship mortgages, it does not preclude supplemental private self-help remedies exercised under state law. The court reasoned that contractual self-help provisions remain valid if they comply with state statutes, such as those governing chattel mortgages, and that questions about the validity of a deficiency judgment after private foreclosure must be resolved in state court rather than federal admiralty jurisdiction.
The case involved a dispute over the loss of a 25-foot vessel during ocean transport from St. Michael, Alaska to Seattle, Washington, where plaintiffs Yutana Barge Lines and its president sought to recover the cargo's value from defendant Northland Services after the barge capsized in a storm. The court held the carrier liable for the full loss, finding a breach of the contract of carriage. The core reasoning was that transporting the cargo via tandem tow without the shipper's prior consent constituted an unreasonable deviation that substantially increased the risk of loss, as confirmed by the carrier's own marine insurance policy requiring single tow in the Gulf of Alaska; under established maritime precedents, such a deviation makes the carrier an insurer and eliminates protections from contractual or statutory liability limits. Defenses based on the tariff, bill of lading terms, and laches were considered but did not alter the outcome on liability.
