Ballard Shipping Co. v. Beach Shellfish

32 F.3d 623, 1994 AMC 2705 (1994)

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Ballard Shipping Co. v. Beach Shellfish

United States Court of Appeals for the First Circuit
32 F.3d 623, 1994 AMC 2705 (1994)

Facts

An oil tanker owned by Ballard Shipping Co. (Ballard) (plaintiff) ran aground in Narragansett Bay, Rhode Island, spilling 300,000 gallons of oil into the bay. One of the results of the accident was the pollution of the bay’s shellfish grounds, which necessitated stopping all shellfishing activities for two weeks. Numerous civil and criminal suits arose from the accident. Ballard filed a petition in federal district court under admiralty jurisdiction seeking to limit its liability. Beach Shellfish (claimant), a group of shellfish dealers whose businesses were harmed by the accident, asserted claims for purely economic losses against Ballard in that admiralty action. Beach Shellfish brought both federal claims for negligence under general maritime law and state claims under a Rhode Island statute that allowed compensation for economic losses from oil spills. The district court dismissed Beach Shellfish’s federal claims based on the ruling of the United States Supreme Court in Robins Dry Dock & Repair Co. v. Flint and held that the state claims were preempted by Robins and must therefore also be dismissed. Beach Shellfish appealed.

Rule of Law

Issue

Holding and Reasoning (Boudin, J.)

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