Cases

Deno v. Progressive Casualty Insurance Co.

Court

5th Cir

Publish Date

03/05/2026
The Fifth Circuit Court of Appeals affirmed dismissal of a yacht owner’s petition to limit liability arising from a marina fire and explosion, holding that the district court lacked admiralty jurisdiction because the incident occurred on Grapevine Lake, an artificial, landlocked reservoir located entirely within Texas and blocked by a dam, which therefore does not constitute “navigable waters” capable of supporting interstate maritime commerce under controlling precedent.
yacht insurance, Limitation of Liability Act, 46 U.S.C. §§ 30501, admiralty jurisdiction, navigable waters, FRCP 12(b)(1), interstate maritime commerce