Washington State Department of Transporation v. Sea Coast Towing Inc.

MEMORANDUM *

In this admiralty case, Plaintiff-Appellant Washington State Department of Transportation appeals the district court’s judgment, following a bench trial, limiting the liability of Defendant-Appellee Sea Coast Towing, Inc. to $105,000, the value of its tugboat CHINOOK. We have jurisdiction under 28 U.S.C. § 1291 . We review the district court’s legal conclusions de novo, see Lentini v. Cal. Ctr. for the Arts, Escondido, 370 F.3d 837, 843 (9th Cir.2004), and we reverse.

The question we must decide is whether the district court erred in its application of the burden-shifting framework required under the Limitation of Liability Act, 46 U.S.C. app. § 183 (1952 & Supp.2005). The Limitation of Liability Act permits a vessel owner to limit its liability for any loss, damage, or injury caused by the vessel to the “amount or value of the interest of such owner in such vessel, and her freight then pending.” Id. § 183(a).

When a vessel owner asserts its claim to limited liability under the Act, a burden-shifting framework is employed to evaluate the shipowner’s eligibility for limited liability. First, the party seeking to recover damages must demonstrate the shipowner’s…