Great Lakes Insurance SE v. Andersson, No. 23-1359 (1st Cir. 2023)
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In this case, Defendant-Appellee Martin Andersson purchased an insurance policy for his vessel from Plaintiff-Appellant Great Lakes Insurance SE. The vessel ran aground off the coast of the Dominican Republic, and Great Lakes brought a declaratory judgment action to determine coverage under the policy. Andersson filed counterclaims for breach of contract and equitable estoppel. Great Lakes' motion for summary judgment was denied, and Andersson was granted partial summary judgment on his breach of contract claim. Great Lakes appealed, claiming the district court erred in refusing to apply the policy's definition of seaworthiness.
The United States Court of Appeals for the First Circuit held that under the absolute implied warranty of seaworthiness, the insured vessel must be seaworthy at the policy's inception, and if not, the policy is void. The court affirmed the district court's ruling, stating that Great Lakes' argument that the absolute implied warranty required the vessel to carry up-to-date charts for all geographic areas covered by the policy in order to be considered seaworthy was unsupported by admiralty case law and was unreasonable.
Additionally, the court held that Great Lakes' argument that the express terms of the policy required updated paper charts for every location that could be navigated under the entirety of the policy coverage area was unsupported by the express language of the policy itself. The court found no precedent supporting the claim that updated paper charts for every location covered by the policy were required to be onboard the vessel at the inception of the policy. As a result, the Court of Appeals affirmed the district court's decision in favor of Andersson.
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