Blake Marine Grp. v. CarVal Investors LLC, No. 15-3115 (8th Cir. 2016)
Annotate this CaseBlake filed suit against CarVal and Lux, alleging tortious interference with Blake's contract to lease a barge and crane to a third party. The district court dismissed the complaint as time-barred. To determine the applicable limitations period the court looked to the choice of law rules of the forum state, which in this case is Minnesota. The court concluded that Alabama's interest in compensating Blake, a resident of that state, outweighs Minnesota's interest and favors the application of Alabama law. Therefore, the court concluded that the fourth choice of law factor favors the application of Alabama law. Since this is the only factor which favors either state's law, the district court did not err by applying Alabama law and dismissing Blake's claim as time barred. The court also concluded that Blake waived its argument that the district court should apply the "fairness exception" to Minnesota's borrowing statute; Blake has not satisfied the first requirement for invoking federal admiralty jurisdiction - the alleged tort occurred on navigable waters - and that laches does not apply; and there was no fraudulent concealment of facts and thus no basis to toll the two year limitations period. Accordingly, the court affirmed the judgment.
Court Description: Murphy, Author, with Shepherd, Circuit Judge, and Perry, District Judge] Civil case - Torts. In an action by an Alabama corporation alleging defendant tortiously interfered with a contract between plaintiff and a third party, the district court did not err in applying Alabama, rather than Minnesota law, as Alabama's interest in protecting its resident outweighed Minnesota's interest in compensating nonresident plaintiffs; nor did the court err in finding the action was barred by Alabama's two-year statute of limitations; since plaintiff had not shown that admiralty jurisdiction was invoked by the alleged tort, the federal admiralty doctrine of laches did not apply; there was no fraudulent concealment of facts which would justify tolling the statute of limitations.
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