Tundidor v. Miami-Dade County, No. 15-12597 (11th Cir. 2016)Annotate this Case
Plaintiff filed suit against the County after he suffered injuries while aboard a vessel traveling in the Coral Park Canal, a drainage canal in the County. The district court dismissed the complaint for lack of subject-matter jurisdiction. At issue is whether a canal is navigable for purposes of admiralty jurisdiction, 28 U.S.C. 1333, if an artificial obstruction prevents vessels from using the canal to conduct interstate commerce. Because the Coral Park Canal cannot support interstate commerce, the court concluded that it cannot satisfy the location requirement of admiralty jurisdiction. The court concluded that extending jurisdiction to waters incapable of commercial activity serves no purpose of admiralty jurisdiction. Therefore, the court agreed with the district court that plaintiff's injuries did not occur on navigable waters for purposes of admiralty jurisdiction because an artificial obstruction prevents vessels from traveling from the Coral Park Canal to places outside of Florida.