Reported / Citable
Background
Plaintiff Adventuras de Pescado, LLC operates a 61-foot Viking sport fishing vessel (M/Y CALIENTE) moored at Marina Pez Vela in Costa Rica. On April 29, 2024, defendant Stoney Barton’s 63-foot Hatteras (M/Y FARTHER & SUN) struck the moored vessel while departing its slip. The collision caused substantial damage to the plaintiff’s hull, resulting in repair costs of $46,158.34. Barton made a partial payment of $13,879.00, leaving a balance of $32,279.34 outstanding.
Plaintiff filed its complaint on May 8, 2025, asserting a general maritime negligence claim. After proper service on August 14, 2025, Barton failed to answer or respond. The clerk entered default on November 3, 2025. Plaintiff then moved for default judgment on February 27, 2026.
The Court’s Holding
The Magistrate Judge recommended granting plaintiff’s motion for default judgment. The court first found that it possessed both subject-matter and personal jurisdiction. Admiralty and maritime jurisdiction existed under 28 U.S.C. § 1333(1) because the vessel collision involved navigable waters and had a substantial relationship to maritime activity. Personal jurisdiction was established over Barton, a Texas resident.
The court determined that default judgment was procedurally warranted. Because Barton failed to appear or respond, he admitted all well-pleaded factual allegations by default. The plaintiff adequately pleaded a maritime negligence claim by alleging: (1) Barton owed a duty of reasonable care; (2) he breached that duty by negligently operating his vessel; (3) the plaintiff sustained injury through damage to its vessel; and (4) the defendant’s negligence caused that injury. Regarding damages, although Barton’s default admitted liability, the court required documentary evidence. The plaintiff supported its damage claim through an affidavit from a company member and repair invoices totaling $46,158.34.
The court awarded $32,279.34 in actual damages (the repair costs minus Barton’s partial payment), prejudgment interest at 3.8% (the Federal Reserve rate) running from April 29, 2024 until judgment entry, postjudgment interest under 28 U.S.C. § 1961, and court costs if properly documented.
Key Takeaways
- Federal courts have admiralty and maritime jurisdiction over vessel collisions occurring in foreign marinas when there is a substantial connection to maritime activity.
- In default judgment proceedings, a defendant’s failure to respond results in admission of all well-pleaded factual allegations, but courts still require documentary evidence to support damage awards.
- Under maritime law, prejudgment interest is the norm rather than the exception and should be awarded unless unusual circumstances make it inequitable; the court may use the Federal Reserve rate as a reasonable guideline.
- A magistrate judge’s recommendation is not final—the district judge retains authority to review and may grant or reject the recommendations.
Why It Matters
This decision clarifies the scope of federal maritime jurisdiction and the procedure for obtaining default judgment in admiralty cases. It demonstrates that even when a defendant defaults, courts maintain gatekeeping functions regarding damages by requiring parties to submit supporting documentation. The case also illustrates the federal court system’s application of maritime law principles—specifically, the presumption that prejudgment interest is appropriate and the use of Federal Reserve rates to establish equitable interest rates.
For practitioners handling maritime disputes, the opinion reinforces that jurisdiction can be established over foreign incidents involving vessels, provided they meet the maritime commerce and nexus requirements. Additionally, it signals that defaulting defendants do not obtain a free pass on damages assessment; plaintiffs must still satisfy evidentiary burdens through invoices, affidavits, and other documentary proof.