Natasha, Inc. v. Evita Marine Charters, Inc.

Summary

The First Circuit held that admiralty jurisdiction extends to the maritime charter provisions of a combined vessel sale and charter agreement when those provisions are readily separable from the nonmaritime sale terms. The court affirmed an award of damages for breach of the charter agreement and imposed double costs and $10,000 in counsel fees because the appeal was frivolous.

Holdings

1. Admiralty jurisdiction exists when the maritime charter obligations in a contract that also contains nonmaritime vessel-sale provisions are divisible and can be separately adjudicated and enforced without prejudice to the nonmaritime provisions.
2. A court of appeals may award double costs and counsel fees when an appeal is frivolous, meaning that the result is obvious or the arguments are wholly without merit.

Questions Presented

1. Whether admiralty jurisdiction exists over the charter portion of a contract that also provides for the sale of a vessel when the charter obligations are readily separable from the nonmaritime sale obligations.
2. Whether the appeal was frivolous and warranted an award of double costs and counsel fees under Federal Rule of Appellate Procedure 38 and 28 U.S.C. § 1912.

Disposition

affirmed