Hunter Marine Group v. Inland Dredging: Limitation of Liability Ruling

This 2026 legal opinion from the United States Court of Appeals for the Fifth Circuit addresses whether a vessel owner can limit financial liability following a maritime accident. The case involves a commercial workboat, the M/V MS Adalyn, which ran aground on the Alabama River while transporting eight employees of a dredging company. Central to the dispute is the Limitation of Liability Act of 1851, which typically protects shipowners but contains a specific exception for covered small passenger vessels. The court had to determine if the injured workers qualified as passengers for hire, even though they did not personally pay for their transport. Ultimately, the judges ruled that indirect consideration paid by an employer satisfies the statutory definition, categorizing the workers as passengers. Consequently, the court affirmed that the owners are denied the protection of the liability limitation because the vessel fits the small passenger craft exception.