No admiralty jurisdiction over contract limited to land transportation, even when cargo being transported was shipped overseas pursuant to maritime “through” bill of lading.
On February 8, 2017, the United States District Court for the District of New Jersey held that it did not have admiralty jurisdiction over a matter involving a contract to lease chassis to a carrier for the transportation of cargo from a railhead to a consignee pursuant to a maritime “through” bill of lading. The plaintiff was in the business of leasing marine equipment (chassis) for the movement of cargo. The defendants used the plaintiff’s chassis to transport ocean import cargo by land pursuant to a “through” bill of lading. The court looked to the nature and character of the contract as set forth by the United States Supreme Court in Norfolk S. Ry. Co. v. Kirby, 543 U.S. 14 (2004) and determined that the subject contract – one to use chassis for the movement of cargo exclusively on land (from railhead to consignee) – was not a maritime contract. Even though the containers placed on the chassis were shipped overseas pursuant to a maritime bill of lading calling for both land and sea transportation, the contract between the plaintiff and the defendants was limited to land transportation. As a result, the court held that it did not have admiralty jurisdiction over the matter.
Case Law Alerts, 2nd Quarter, April 2017
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