Accelerant Specialty Insurance Company v. KKS Marine II, LLC

CourtDistrict Court, S.D. California
DecidedOctober 7, 2024
Docket3:24-cv-00214
StatusUnknown

This text of Accelerant Specialty Insurance Company v. KKS Marine II, LLC (Accelerant Specialty Insurance Company v. KKS Marine II, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Accelerant Specialty Insurance Company v. KKS Marine II, LLC, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 ACCELERANT SPECIALTY Case No.: 24-cv-00214-AJB-AHG INSURANCE COMPANY, 12 Plaintiff, ORDER GRANTING PLAINTIFF’S 13 MOTION TO STRIKE DEFENDANT’S v. JURY TRIAL DEMAND 14 KKS MARINE II, LLC, 15 Defendant. (Doc. No. 11)

16 Presently pending before the Court is Plaintiff Accelerant Specialty Insurance Co.’s 17 motion to strike Defendant KKS Marine II, LLC’s jury trial demand. (Doc. No. 11.) KKS 18 filed an opposition to the motion, (Doc. No. 15), to which Plaintiff replied, (Doc. No. 19). 19 Pursuant to Civil Local Rule 7.1.d.1, the Court finds the instant matter suitable for 20 determination on the papers and without oral argument. For the reasons stated herein, the 21 Court GRANTS the motion to strike KKS’s jury trial demand. 22 I. BACKGROUND 23 Plaintiff issued an insurance policy covering KKS’s yacht, named the Life Doesn’t 24 Suck (“Vessel”). (Complaint (“Compl.”), Doc. No. 1, ¶¶ 5, 9.) In May 2023, the Vessel’s 25 port engine overheated, and KKS filed an insurance claim with Plaintiff. (Id. ¶¶ 8, 15.) 26 Plaintiff ultimately denied KKS’s insurance recovery claim. (Id. ¶ 22.) 27 /// 28 1 On January 31, 2024, the same day Plaintiff denied KKS’s insurance claim, Plaintiff 2 filed its Complaint, seeking Declaratory Judgment on three counts asserting various 3 breaches and lack of coverage under the insurance policy at issue. (See generally id.) 4 Plaintiff alleges the case is an admiralty and maritime case within the meaning of Federal 5 Rules of Civil Procedure 9(h) and 38(e), and this Court has subject matter jurisdiction 6 pursuant to 28 U.S.C. § 1333. 7 On March 25, 2024, KKS filed its Answer and two Counterclaims, alleging Plaintiff 8 improperly denied coverage under the insurance policy at issue. (See Doc. No. 9.) In its 9 Answer, KKS “admits the Court has subject matter jurisdiction over this action pursuant 10 to 28 U.S.C. § 1333.” (Id., Answer ¶ 2.) Moreover, KKS asserts “[t]his Court has 11 supplemental jurisdiction over Defendant’s counterclaims pursuant to 28 U.S.C. 12 § 1367(a).” (Id., Counterclaim ¶ 4.) KKS requests monetary damages and that its first 13 counterclaim for breach of contract against Plaintiff be tried to a jury. (Id., Prayer for Relief 14 ¶ A.) 15 Plaintiff filed this motion to strike KKS’s demand for trial by jury, arguing Plaintiff 16 elected to proceed in admiralty and there is no right to a jury in an action brought under 17 admiralty or maritime jurisdiction. (Doc. No. 11.) 18 II. DISCUSSION 19 Plaintiff argues that because this case was brought in admiralty, KKS has no right to 20 a jury trial. (Doc. No. 11.) KKS counters that even though Plaintiff elected to proceed in 21 admiralty, an independent, non-admiralty jurisdictional basis exists, entitling it to a jury 22 trial. (Doc. No. 15 at 6.) Specifically, KKS asserts that its counterclaim for breach of 23 contract is “one that could traditionally have been brought at common law” and this Court 24 has an independent basis for jurisdiction over that claim based on diversity jurisdiction. 25 (Id. (quoting Craig v. Atl. Richfield Co., 19 F.3d 472, 476 (9th Cir. 1994)).) 26 District courts have original jurisdiction over “[a]ny civil case of admiralty or 27 maritime jurisdiction, saving to suitors in all cases all other remedies to which they are 28 otherwise entitled.” 28 U.S.C. § 1333(1). The “saving to suitors” clause leaves state courts 1 “competent” to adjudicate maritime causes of action for in personam proceedings and 2 allows plaintiffs to bring an action at law in federal district court, provided that the 3 requirements for diversity jurisdiction under 28 U.S.C. § 1332 are met. Ghotra by Ghotra 4 v. Bandila Shipping, Inc., 113 F.3d 1050, 1054 (9th Cir. 1997). A plaintiff seeking to bring 5 in personam maritime claims thus has three options: file a suit in federal court under federal 6 admiralty jurisdiction, in federal court under diversity jurisdiction if the parties are diverse 7 and the amount in controversy is satisfied, or in state court. Id. Although the difference 8 between these options “is mostly procedural,” the “greatest significance is that there is no 9 right to jury trial if general admiralty jurisdiction is invoked, while it is preserved for claims 10 based in diversity or brought in state court.” Id. (citing Fed. R. Civ. P. 38). Where both 11 admiralty and non-admiralty federal jurisdiction exist, a pleader may designate a claim as 12 an admiralty claim under Federal Rule of Civil Procedure 9(h) to inform the court that the 13 pleader elects to proceed within the court’s admiralty jurisdiction. 14 There is a “lack of consensus” among federal courts as to whether a defendant 15 bringing compulsory legal counterclaims in response to a plaintiff’s admiralty claim is 16 entitled to a jury trial. Great Lakes Ins. SE v. Andersson, 525 F. Supp. 3d 205, 207 (D. 17 Mass. 2021). Under Ninth Circuit precedent, “where a federal court has an independent 18 basis of jurisdiction over cases involving admiralty claims, such as diversity of citizenship, 19 both the defendant and plaintiff have a right to demand a jury trial under the Seventh 20 Amendment so long as the suit is one that could traditionally have been brought ‘at 21 common law’. . . .”). Craig, 19 F.3d at 476 (emphases added). 22 Here, Plaintiff asserted subject matter jurisdiction only under this Court’s admiralty 23 jurisdiction, 28 U.S.C. § 1333(1). (Compl. ¶ 2.) Plaintiff did not assert any other basis for 24 federal subject matter jurisdiction and made a Rule 9(h) election indicating its intent to 25 proceed under admiralty despite independent bases of jurisdiction over its claims. (Id.) 26 Although courts have found that independent jurisdiction exists where a party has asserted 27 diversity jurisdiction, KKS has not done so here. Cf. Ghotra by Ghotra, 113 F.3d at 1058 28 (“Ghotras clearly asserted diversity as the jurisdictional basis for the in personam claims 1 in each of their Complaints.”). For that reason, KKS’s reliance on Wilmington Trust v. U.S. 2 District Court for the District of Hawaii, 934 F.2d 1026, 1027–28 (9th Cir. 1991), where 3 the defendant asserted “[i]ndependent jurisdictional grounds” for each counterclaim, is 4 misplaced. KKS’s reliance on Clear Spring Property & Casualty Co. v. Arch Nemesis, 5 LLC, No. 22-CV-2435-DDC-TJJ, 2023 WL 6200198, at *9 (D. Kan. Sept. 22, 2023); 6 Sphere Drake Insurance PLC v. J. Shree Corp., 184 FRD 258, 261 (S.D.N.Y. 1999); and 7 Canal Barge Co. v. Commonwealth Edison Co., No. 98 C 0509, 2002 WL 206054, at *3 8 (N.D. Ill. Feb. 11, 2002), fail for the same reasons. Moreover, while the court in Craig did 9 not elaborate on whether any party in that case pled diversity jurisdiction, the court noted 10 that the issue had previously been ruled on. 19 F.3d at 476. 11 KKS further asserts it was not required to plead diversity jurisdiction in its 12 counterclaims because the question is whether the court “has an independent basis for 13 jurisdiction.” (Doc. No.

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Accelerant Specialty Insurance Company v. KKS Marine II, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/accelerant-specialty-insurance-company-v-kks-marine-ii-llc-casd-2024.