Kel-Sea Adventures LLC v. Contender Boats, Inc. and Great American Insurance Company

CourtLouisiana Court of Appeal
DecidedSeptember 26, 2024
Docket2024CA0208
StatusUnknown

This text of Kel-Sea Adventures LLC v. Contender Boats, Inc. and Great American Insurance Company (Kel-Sea Adventures LLC v. Contender Boats, Inc. and Great American Insurance Company) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kel-Sea Adventures LLC v. Contender Boats, Inc. and Great American Insurance Company, (La. Ct. App. 2024).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2024 CA 0208

KEL- SEA ADVENTURES LLC

allff- M-1

CONTENDER BOATS, INC. AND GREAT AMERICAN INSURANCE GROUP

Judgment Rendered:

On Appeal from the Twenty -First Judicial District Court In and for the Parish of Tangipahoa State of Louisiana Docket No. 2022- 0002767, Div. C

Honorable Erica W. Sledge, Judge Presiding

Gino J. Rendeiro Counsel for Plaintiff/Appellant David E. Kavanagh Kel- Sea Adventures LLC New Orleans, Louisiana

Aaron B. Greenbaum Counsel for Defendant/ Appellee Salvador J. Pusateri Contender Boats, Inc. Kristian B. Dobard New Orleans, Louisiana

Christopher E. Carey Counsel for Defendant/ Appellee New Orleans, Louisiana Great American Insurance Group McCLENDON, J.

Plaintiff-appellant, Kel- Sea Adventures LLC ( Kel- Sea), appeals the trial court' s

judgment rendered in favor of defendant -appellee, Contender Boats, Inc. ( Contender),

sustaining Contender's objection of lack of personal jurisdiction and dismissing Kel- Sea' s

claims against Contender. The issue before this court is whether the assertion of personal

jurisdiction by Louisiana over Contender complies with the limits of constitutional due

process. Finding that it does not, we affirm.

FACTS AND PROCEDURAL HISTORY

Defendant -appellee, Contender, a Florida corporation with its principal place of

business in Homestead, Florida, designs and manufactures fishing vessels " solely in the

State of Florida." The lawsuit underlying this appeal concerns a fishing vessel originally

built by Contender for Intensity Offshore Outfitters, LLC ( Intensity), a Louisiana limited

liability company, and subsequently purchased from Intensity by plaintiff-appellant Kel-

Sea, also a Louisiana limited liability company.

In February 2016, Josh Bodenheimer attended the Miami Boat Show in Miami,

Florida, on behalf of Intensity. While at the Miami Boat Show, Mr. Bodenheimer made

contact with representatives of Contender and placed an order for the purchase of a

fishing vessel. Contender manufactured the subject 2017 39' Contender 39ST fishing vessel, hull identification number: JDJ9V109F617 ( the Vessel), solely within Florida. The

work order, invoice, and supplemental invoice all reflected that the Vessel was to be sold

to Intensity, located in Metairie, Louisiana, and shipped to Intensity, " F. O. B." Homestead, Florida.' After Intensity paid for the Vessel via a bank wire transfer directed to

Contender's Florida bank account, 2 Contender made delivery of the Vessel to Intensity in

Florida and issued a Limited Warranty Statement in favor of "the original ... owner[]" of

the Vessel.

I " FOB" is an abbreviation for " FREE ON BOARD[,]" a term which denotes that the seller's delivery is complete, and the risk of loss passes to the buyer, when the goods pass into the transporter's possession. See Black's Law Dictionary ( 12th ed. 2024). Stated differently, " F. O. B." means title is transferred at the time goods are delivered to the carrier. See Lowe' s Home Center, Inc. v. Kennedy, 32, 443 ( La. App. 2 Cir. 10/ 27/ 99), 744 So. 2d 711, 713.

2 The original purchase price of the Vessel is redacted from the record. Giving rise to the lawsuit underlying this appeal, Kel- Sea purchased the Vessel

from Intensity for the price of $300, 000. 00 on or about July 31, 2018. After inspections

of the Vessel allegedly revealed manufacturing defects, Kel- Sea filed a petition for

damages in the 21st Judicial District Court in Tangipahoa Parish on September 12, 2022.

The petition alleged the Vessel " sustained severe and permanent damages as a result of

manufacturing and/ or design defects and/ or manufacturing inadequacies through normal

and foreseeable use," which rendered the Vessel a " constructive total loss." Continuing,

the petition alleged Kel- Sea sustained economic damages from loss of the use of the

Vessel and the resulting loss of revenue. The petition further alleged that Contender, as

the Vessel' s manufacturer, and Great American Insurance Group, as Kel- Sea' s insurer for

damages and losses sustained due to marine perils, were liable to Kel- Sea pursuant to

the Louisiana Products Liability Act, LSA- R. S. 9: 2800. 51, et seq., as well as theories of

negligence and breach of contract/ warranty. Kel- Sea did not name Intensity as a party

to the underlying lawsuit.

Contender responded to Kel- Sea' s petition on January 13, 2023. 3 Contender filed

an answer, a declinatory exception pleading the objection of lack of personal jurisdiction,

a peremptory exception pleading the objection of no cause of action, and a peremptory

exception pleading the objection of no right of action. 4 Of these exceptions, only

Contender's exception of lack of personal jurisdiction is at issue in this appeal. In that

regard, Contender asserted that it was a Florida corporation, with a principal place of

business in Florida, and built boats solely in Florida; that it had no offices, employees, or

property in Louisiana; and that all of the activity related to the manufacture of the Vessel,

as well as the sale and delivery of the Vessel to the original purchaser, occurred in Florida.

Maintaining that these contacts with Louisiana did not constitute sufficient minimum

3 Great American Insurance Group also answered the petition and asserted exceptions and defenses, but is not a party to this appeal.

4 Louisiana Code of Civil Procedure article 922 recognizes three exceptions: the declinatory exception, the dilatory exception, and the peremptory exception. At issue in this appeal is a declinatory exception raising the objection of the court's lack of jurisdiction over the person of the defendant. See LSA- C. C. P. art. 925( A)( 5). Herein, for brevity, we refer to same as an exception of lack of personal jurisdiction. Likewise,

we refer to the peremptory exceptions raising the objections of no cause of action and no right of action as exceptions of no cause and no right of action. See LSA- C. C. P. art. 927( 5) and ( 6).

3 contacts to subject Contender to personal jurisdiction in Louisiana, Contender sought

dismissal of Kel- Sea' s claims.

Kel- Sea opposed Contender' s exceptions in a memorandum filed on April 27, 2023.

Regarding the exception of lack of personal jurisdiction at issue herein, Kel- Sea argued

Contender had established minimum contacts with Louisiana because Contender was

registered to do business in Louisiana and had maintained long- term authorized dealer

relationships with boat dealerships in Louisiana. Thus, Kel- Sea maintained Contender had

benefitted from " a substantial physical presence in Louisiana ... through the sales and

service of its vessels and through the significant activities of its authorized dealer agents"

in Louisiana for many years, including the period of time when the Vessel was built.

Contender filed a reply memorandum in support of its exceptions on June 8, 2023,

specifically addressing the arguments Kel- Sea raised in its opposition memorandum. 5

Contender conceded that it was registered to do business in Louisiana and previously had

an authorized dealership relationship with a Louisiana boat dealership, but denied that

Contender or its authorized dealer directed any activity into Louisiana related to the

original purchase of the Vessel.

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Kel-Sea Adventures LLC v. Contender Boats, Inc. and Great American Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kel-sea-adventures-llc-v-contender-boats-inc-and-great-american-lactapp-2024.