WILLIAM BECKMAN, APPELLANT,
v.
RICK'S WATERCRAFT RENTALS, ETC., ET AL., APPELLEES
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
William Beckman sued the manufacturer and rental company for injuries sustained in a jet ski accident in navigable waters off the Florida Keys. The trial court dismissed his claim as time-barred under the three-year maritime statute of limitations rather than the four-year Florida statute, and the appellate court affirmed, holding that personal injury claims arising from accidents on seagoing craft constitute maritime claims.
The court held that the claim is a maritime claim governed by the three-year federal statute of limitations under 46 U.S.C.A.App. § 763a. Personal injury claims arising from accidents involving seagoing craft on navigable waters qualify as maritime claims when there is a realistic potential for disruptive impact on maritime commerce, even when no other vessel is involved and the alleged negligence occurs on land.
[1] An incident on navigable waters involves a maritime claim if it has a "realistic potentially disruptive impact on maritime commerce."
[2] An accident causing serious injury to an occupant of a seagoing craft qualifies as a maritime claim, even if no other vessel is involved and the alleged negligence occurr…
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“In the case of an incident on navigable waters, the issue of whether a "maritime" claim is involved turns on whether the accident involved a realistic "potentially disruptive impact on maritime commerce."”
Establishes the legal standard for determining whether a claim is maritime or state-based
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceOn January 4, 1993, Beckman severely injured his knee when he lost control of a rented jet ski in navigable waters off the Florida Keys. He sued Yamah…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Negligent Design cases and more on FLexlaw
SCHWARTZ, Chief Judge.
On January 4,1993, Beckman severely injured himself when he struck his knee after he lost control of a jet ski in navigable waters off the Florida Keys.
On December 27, 1996, he sued Yamaha, the manufacturer of the “vessel,” see Keys Jet Ski, Inc. v. Kays, 893 F. 2d 1225 (11th Cir.1990), and those who had rented it to him, alleging that they had respectively negligently designed the watercraft, did not adequately warn of its dangers, and failed properly to instruct him on its operation.
The trial court ruled that the action involved a maritime claim therefore governed by the three-year maritime statute of limitations, 46 U.S.C.A.App. § 763a (West 1998), rather than, as Beckman claimed, a Florida cause of action subject to the four-year statute of limitations provided by section 95.11(3)(a), Florida Statutes (1997).
Accordingly, the action was dismissed as time-barred.
We affirm.
In the case of an incident on navigable waters, the issue of whether a “maritime” claim is involved turns on whether the accident involved a realistic “potentially disruptive impact on maritime commerce.” See Sisson v. Ruby, 497 U.S. 358, 362, 110 S.Ct. 2892, 2896, 111 L.Ed.2d 292, 299 (1990).
The decided cases clearly establish that an accident like this one, which causes a serious injury to an occupant of a seagoing craft— even if no other vessel is involved and the defendants’ alleged negligence occurs on land — fully qualifies under this definition. See Mink v. Genmar Indus., Inc., 29 F. 3d 1543, 1546 (11th Cir.1994)(“Mmfc could have fallen forward, striking the pilot or controls, thus directly interfering with the navigation of the craft and potentially causing an accident with another craft. Or, the disruption of a serious passenger injury within such intimate confines could have distracted the pilot and directly interfered with the navigation of a vessel. We readily conclude that there was a potential hazard to maritime commerce.”); Sinclair v. Soniform, Inc., 935 F. 2d 599, 602 (3d Cir.l991)(“If the crew had been aware of Sinclair’s need for immediate medical assistance, they may have signaled to other vessels in the area for assistance. The possibility that commercial vessels would be diverted to respond to such a distress signal was certainly as great as the potential relied upon by the Supreme Court in Foremost [Ins. Co. v. Richardson, 457 U.S. 668, 102 S.Ct. 2654, 73 L.Ed.2d 300 (1982) ] that commercial vessels would be diverted by the collision of two pleasure crafts.”); Barber v. Marina Sailing, Inc., 36 Cal.App.4th 558, 42 Cal.Rptr.2d 697 (1995)(on board passenger caught in dock lines while easting off could have required rescue efforts that would have impeded commercial activities at dock), review denied (October 19, 1995); Miami Valley Broadcasting Corp. v. Lang, 429 So. 2d 1333 (Fla. 4th DCA 1983)(passenger in pleasure boat on intercoastal thrown from seat in boat onto deck); Cigarette Racing Team, Inc. v. Gandee, 418 So. 2d 337 (Fla. 3d DCA 1982)(pleasure boat passenger on intercoastal thrown from boat and injured face when boat hit wake), pet. for review denied, 427 So. 2d 736 (Fla.1983).
See generally Foremost Ins. Co. v. Richardson, 457 U.S. 668, 102 S.Ct. 2654, 73 L.Ed.2d 300 (1982); Lipworth v. Kawasaki Motors Corp., 592 So. 2d 1151 (Fla. 4th DCA 1992), review denied, 601 So. 2d 552 (Fla.1992), cert. denied, 506 U.S. 974, 113 S.Ct. 465, 121 L.Ed.2d 373 (1992).
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Hopkins v. THE Boat Club, Inc., 866 So. 2d 108 (Fla. 1st DCA 2004)…e trial court agreed and entered the final summary judgment under review.1 This case falls within the contours of federal maritime jurisdiction. See [*111] Borden v. Phillips, 752 So. 2d 69 (Fla. 1st DCA 2000); Beckman v. Rick’s Watercraft Rentals, 719 So. 2d 1025 (Fla. 3d DCA 1998); Mink v. Genmar Industries, 29 F. 3d 1543 (11th Cir.1994).2 Federal maritime law controls the rights and liabilities of the parties in such cases. See Diesel "Repower," Inc. v. Islander Investments, 271 F. 3d 1318 (11th Cir.2001).…
Authorities Cited
- Foremost Ins. Co. v. Richardson, 457 U.S. 668 (U.S. 1982)
- Sisson v. Ruby, 497 U.S. 358 (U.S. 1990)
- In re the Complaint of Keys JET SKI, Inc. v. Kays, 893 F.2d 1225 (Fed. Cir. 1990)
- Mink v. Genmar Indus., Inc., 29 F.3d 1543 (11th Cir. 1994)
- Sinclair v. Soniform, Inc., 935 F.2d 599 (3d Cir. 1991)
- Cigarette Racing Team, Inc. v. Sonny Gandee & Gandee & Assocs., Inc., 418 So. 2d 337 (Fla. 3d DCA 1982)
- Lipworth v. Kawasaki Motors Corp. U.S.A., 592 So. 2d 1151 (Fla. 4th DCA 1992)
- Miami Valley Broad. Corp. v. Lincoln Lang, 429 So. 2d 1333 (Fla. 4th DCA 1983)
- Murphy v. Sullivan, 506 U.S. 974 (U.S. 1992)
- Sakaria v. Allstate Life Ins. Co., 506 U.S. 974 (U.S. 1992)