Sea Hunt, Inc. v. Unidentified Shipwrecked Vessel

Sea Hunt, Inc. (plaintiff) was a marine-salvage company that had obtained permits from the state of Virginia to locate shipwrecks off the Virginia coast and conduct salvage operations on the wrecks. Sea Hunt located two shipwrecks, La Galga and the Juno (defendants), Spanish naval vessels that were lost in the 1700s. Sea Hunt initiated an in rem action in admiralty in federal district court against the two wrecks, seeking a declaratory judgment that the wrecks had been abandoned by Spain and were therefore owned by the state of Virginia and subject to Sea Hunt’s salvage permits. The district court issued an order directing the arrest of the vessels and granting Sea Hunt exclusive rights of salvage but also directed Sea Hunt to provide notice of the action to the United States and to Spain. The United States moved to intervene and file a claim on Spain’s behalf, on the grounds that because United States vessels could only be abandoned by express action, it was bound by treaty to treat Spanish vessels the same. The district court found that the United States lacked authority to appear on Spain’s behalf but granted Spain time to respond. Spain’s response asserted ownership of the vessels and denied that the vessels had ever been abandoned. The district court found that Spain had abandoned its claim to La Galga in a 1763 treaty but that it retained ownership of the Juno and had expressly refused any continuation of Sea Hunt’s salvage efforts. Spain appealed the judgment as to La Galga, and Sea Hunt and Virginia appealed with regard to the Juno.