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Travelers Property Casualty Co. of Americav.Ocean Reef Charters, LLC

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.19-13690
DecidedMay 6, 2021
Reporter996 F.3d 1161 (11th Cir. 2021)
JudgesAdalberto Jordan, Jill A. Pryor, and Andrew L. Brasher, Circuit Judges
Tags
CivilInsurance LawContract InterpretationStatutory InterpretationFirst ImpressionReversalRemand
Case Summary

Ocean Reef Charters insured its yacht under a policy requiring a full-time approved captain and professional crew. When Hurricane Irma struck Florida, the yacht lacked both, sank at its dock, and became a constructive total loss. Travelers denied coverage, arguing that federal maritime law strictly enforced the warranties regardless of whether their breach caused the loss. The district court granted Travelers summary judgment. The Eleventh Circuit held that no entrenched federal maritime rule governed captain or crew warranties. Although earlier circuit decisions recognized strict rules for particular navigation and seaworthiness warranties, they did not establish a universal rule for every marine-insurance warranty, and the Supreme Court’s decision in Wilburn Boat required examining the specific warranty at issue. Florida law therefore governed, including its rule that a breach defeats coverage only if it increased the hazard within the insured’s control. The court reversed the summary judgment and remanded for the district court to apply Florida law and address related arguments.

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