Travelers Property Casualty Company of America v. Ocean Reef Charters LLC, No. 19-13690 (11th Cir. 2021)Annotate this Case
The district court held on summary judgment that, under Eleventh Circuit precedent, federal maritime law requires strict compliance with captain and crew warranties in a marine insurance policy. The district court concluded that, because Ocean Reef breached those warranties, there was no coverage for the loss of its yacht under a policy issued by Travelers.
The Eleventh Circuit applied Wilburn Boat Co. v. Firearm’s Fund Ins. Co., 348 U.S. 310, 316 (1955), and concluded that there does not exist entrenched federal maritime rules governing captain or crew warranties in this case. Therefore, Florida law applies to determine the effect of Ocean Reef's breaches. The court reversed and remanded for further proceedings.