In re: William Crutchfield
OPINION AND ORDER by Judge Terence Kern , dismissing/terminating case (terminates case) (Re: 2 Complaint ) (Documents Terminated: 107 MOTION For Exoneration of Petitioner William Crutchfield ) (lmc, Chambers)
IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF OKLAHOMA
IN THE MATTER OF THE
THE COMPLAINT OF WILLIAM
CRUTCHFIELD FOR EXONERATION
FROM, OR LIMITATION OF,
Case No. 16-CV-255-TCK-FHM
OPINION AND ORDER
Before the Court is Petitioner William Crutchfield’s Motion for Exoneration (Doc. 107).
Petitioner seeks exoneration from liability arising from a March 27, 2016 fire involving his
boat on Keystone Lake in Sand Springs, Oklahoma. Several parties filed claims during a Courtsupervised claim period, and several of these claimants subsequently filed motions to dismiss for
lack of subject-matter jurisdiction. However, before the Court ruled on the motions to dismiss, all
parties requested a stay of this proceeding while settlement discussions were in progress. Petitioner
ultimately reached agreements with all parties to stipulate to the dismissal of their claims. After all
claims were dismissed, Petitioner filed the Motion for Exoneration.
After reviewing the Motion for Exoneration, the Court ordered Petitioner to show cause why
his Complaint should not be dismissed for lack of subject-matter jurisdiction, noting that claimants’
motions to dismiss raised substantial questions about the existence of jurisdiction. Although
Petitioner’s Complaint stated that jurisdiction is based on 28 U.S.C. § 1331 (federal question) and
1333 (admiralty), Petitioner appears to have abandoned any theory of jurisdiction under these
The procedural history of this case is summarized in further detail in the Court’s
March 21, 2018 Order (Doc. 108).
statutes. Instead, Petitioner’s response argues that the Shipowner’s Limitation of Liability Act, 46
U.S.C. §§ 30501-30512 (the “Limitation Act”) provides an independent basis for federal
jurisdiction. (Doc. 109 (“Response”).)
The undersigned has previously rejected the argument that the Limitation Act provides
federal jurisdiction in the absence of traditional admiralty jurisdiction. See In re Compl. of Special
Explor’n Co., Inc., and John F. Special, No. 07-CV-224-TCK-SAJ, Doc.107, slip op. at 7-8 (N.D.
Okla. Feb. 22, 2008) (report and recommendation adopted at Doc. 115 (Sept. 30, 2008)) (citing
Guillory v. Outboard Motor Corp., 956 F.2d 114, 115 (5th Cir. 1992)) (“The Limitation Act . . . does
not provide an independent basis for jurisdiction in federal court. Admiralty jurisdiction must be
present before the Limitation Act applies.”). The Tenth Circuit has not addressed whether the
Limitation Act independently confers federal jurisdiction, but other circuit courts have held
uniformly that it does not. See, e.g., MLC Fishing, Inc. v. Velez, 667 F.3d 140, 143 (9th Cir. 2011)
(“Having carefully considered the question, we take this occasion to join our sister Circuits in
holding that the Limitation Act does not confer admiralty jurisdiction over petitions that arise from
incidents that, like the one here, did not occur on or over navigable waters.”); Guillory, 956 F.2d at
115 (“The Limitation of Liability Act does not confer jurisdiction upon federal courts. That must
come from our admiralty jurisdiction under U.S. Const. art. III, § 2 and 28 U.S.C. § 1333(1).”);
David Wright Charter Serv., Inc. v. Wright, 925 F.2d 783, 785 (4th Cir. 1991) (“In concert with the
Seventh, Eighth, and Eleventh Circuits, we conclude that the Limitation Act is not a source of
admiralty jurisdiction. Rather it is a procedure that may be invoked when general admiralty and
maritime jurisdiction has been established.”); Three Buoys Houseboat Vacations USA Ltd. v. Morts,
921 F.2d 775, 779 (8th Cir. 1990) (holding that the Limitation Act does not create federal question
jurisdiction because it is in the nature of a defense); see also Tandon v. Captain’s Cove Marina of
Bridgeport, Inc., 752 F.3d 239, 244 (2d Cir. 2014) (“[T]he fact that a vessel owner may file a
petition for limitation does not mean the district court necessarily has jurisdiction to hear it. Instead,
the district court will only have admiralty jurisdiction to hear a petition for limitation if it already
has admiralty jurisdiction over the underlying claims that the petition seeks to limit.”).
Petitioner argues that the holding of Richardson v. Harmon, 222 U.S. 96, 106 (1911)
establishes that the Limitation Act provides an independent basis for federal jurisdiction. However,
as noted supra, every circuit court that has considered this question has held that the Limitation Act
does not independently confer jurisdiction. Petitioner contends the Court should instead follow In
re Bernstein, 81 F. Supp. 2d 176 (D. Mass. 1999), in which the district court noted, yet rejected, “the
overwhelming disapproval by the Courts of Appeals” of the argument that the Limitation Act
confers independent jurisdiction. 81 F. Supp. 2d at 182. However, the Court is more persuaded by
the decisions of the courts of appeals that have considered this issue. The other district court cases
relied upon by Petitioner are not controlling and are inapposite for the reasons set forth in
Progressive Northern Insurance Company’s and Progressive Direct Insurance Company’s Reply in
support of their motion to dismiss. (See Doc. 84, at 7-8.) For these reasons, Petitioner has failed
to show that the Court should revisit its previous conclusion that the Limitation Act does not provide
an independent basis for jurisdiction. The Court therefore concludes that it lacks jurisdiction to rule
on Petitioner’s Motion for Exoneration. The Court further finds that Petitioner’s Complaint is
subject to dismissal sua sponte for lack of subject-matter jurisdiction.
For the reasons set forth herein, the Petitioner William Crutchfield’s Complaint (Doc. 2) is
DISMISSED for lack of subject-matter jurisdiction. This Order closes the proceeding and
terminates the Motion for Exoneration (Doc. 107).
SO ORDERED this 26th day of July, 2018.
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