U.S. Court of Appeals for the Fifth Circuit, A&T Maritime Logistics v. RLI Insurance Co., Docket No. 23-30078

Admiralty & Maritime Law

 

Interpretation of a Policy of Marine Insurance

 

Federal Law

 

 

 

 

Federal law generally “governs the interpretation of a policy of marine insurance.” Elevating Boats, Inc. v. Gulf Coast Marine, Inc., 766 F.2d 195, 198 (5th Cir. 1985). If there is no federal statute or general maritime law on an issue, “the law of the state where the marine insurance contract was issued and delivered is the governing law.” Id. The parties agree that Louisiana law, which requires an insurer to demonstrate actual prejudice resulting from delayed notice before it can deny coverage on that ground, provides supplemental rules of decision here. See id. (applying the Louisiana rule).

 

 

As an aside, “traditionally, the term ‘admiralty’ refers to the courts, jurisdiction, and procedure of maritime law, and ‘maritime’ refers to the substantive law itself.” Poincon v. Offshore Marine Contractors, Inc., 9 F.4th 289, 294 n.2 (5th Cir. 2021) (citing David W. Robertson, Steven F. Friedell & Michael F. Sturley, Admiralty and Maritime Law in the United States 4 (3d ed. 2015)). “That distinction has faded over time, and ‘admiralty’ and ‘maritime’ are now used largely synonymously.” Id. (Fn. 6).

 

 

 

 

(U.S. Court of Appeals for the Fifth Circuit, Feb. 4, 2025, A&T Maritime Logistics v. RLI Insurance Co., Docket No. 23-30078)