In re LabMar Inland LLC, et al.

Summary

The Eastern District of Louisiana grants in part a motion to bifurcate proceedings in a maritime limitation action arising from an airboat allision with the M/V MANDY WHIPPLE. The court orders that limitation, liability, and allocation of fault be tried to the bench, while damages will be tried simultaneously to a jury in federal court. The court rejects bifurcation that would have required separate state-court trials because of overlapping evidence, inefficiency, delay, and the risk of inconsistent judgments.

Holdings

1. The requested bifurcation was not appropriate because the limitation, liability, allocation-of-fault, and damages issues substantially overlap and separating them would create duplication, delay, expense, and a risk of inconsistent judgments.
2. The Court bifurcated limitation, liability, and allocation of fault from damages. The first group of issues will be tried to the bench, and damages will be tried simultaneously to a jury in this Court.
3. The petitioners' Rule 14(c) tender properly placed the claimants' claims against Airboat Adventures and Captain Helmer before the Court for adjudication.

Questions Presented

1. Whether the limitation action should be bifurcated so that limitation and petitioners' liability would be tried in federal court and damages and allocation of fault would be tried in state court.
2. Whether bifurcation of limitation, liability, allocation of fault, and damages would promote convenience, expedite and economize the proceedings, or avoid prejudice under Rule 42(b).
3. Whether the Court should instead separate limitation, liability, and allocation of fault from damages and try both phases in federal court, with the first phase to the bench and the damages phase to a jury.

Disposition

other