Riffle v. Carnival Corporation

CourtDistrict Court, S.D. Florida
DecidedApril 18, 2025
Docket1:25-cv-20355
StatusUnknown

This text of Riffle v. Carnival Corporation (Riffle v. Carnival Corporation) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Riffle v. Carnival Corporation, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 25-cv-20355-BLOOM/Elfenbein

MICHAEL RIFFLE,

Plaintiff,

v.

CARNIVAL CORPORATION d/b/a CARNIVAL CRUISE LINE

Defendant. ________________________________/

ORDER ON MOTION TO DISMISS PLAINTIFF’S COMPLAINT THIS CAUSE is before the Court upon Defendant Carnival Corporation’s (“Carnival”) Motion to Dismiss Plaintiff’s Complaint, ECF No. [5] (“Motion”). Plaintiff Michael Riffle filed a Response in Opposition (“Response”), ECF No. [7], to which Carnival filed a Reply, ECF No. [9]. The Court has reviewed the Complaint, the Motion, the Response, the Reply, the record in this case, the applicable law, and is otherwise fully advised. For the reasons set forth below, Carnival’s Motion is denied. I. BACKGROUND Plaintiff filed his Complaint against Carnival under maritime law, asserting a claim for Vicarious Liability (Count I) and Negligence (Count II). See ECF No. [1]. Plaintiff alleges that Carnival is a cruise line company that “owned, operated, maintained, controlled, and possessed a vessel named Carnival Dream,” the cruise ship Plaintiff was aboard when he suffered his injuries. Id. at ¶ 8. Carnival Dream is “equipped with an amusement theme[ ] park for passenger use,” and includes a “waterslide available for passengers to descend.” Id. at ¶ 13. The slide has a shutdown lane designed to slow down riders as they reach the bottom of the slide. See id. at ¶ 18. The base of the “shutdown lane is enclosed on four sides by a blue wall which stands approximately two to three feet tall.” Id. at ¶ 17. The waterslide is under the “exclusive control of [Carnival] and/or its employees.” Id. at ¶ 14. Accordingly, Carnival “has policies and procedures for operation of the waterslide . . . which provide for stationing an attendant at the top and bottom of the slide to ensure

passenger safety and maintenance of the water levels in the slide.” ECF No. [1] at ¶ 19. The policies provide that one of the duties of the attendants is to monitor “water levels in [the] shutdown lane” to “make sure [the] shutdown lane is operating correctly,” and “[d]elay dispatch of [the] next rider until [the] water level is at proper depth.” Id. at ¶ 21. Carnival’s policies and procedures also instruct “employees that ‘shutdown lanes require extra attention to make sure water levels are at correct operating levels, [because] too little or too much depth in the shutdown lane will affect braking distance and characteristics.”’ Id. at ¶ 21. On the day of the incident, Plaintiff decided he would descend Carnival’s waterslide; however, the water levels on the slide were too low. The Carnival employees stationed on the slide nevertheless “deliberately and recklessly instructed Plaintiff to proceed with using the waterslide

. . . presenting a dangerous condition by which a patron on the slide would not be slowed at the bottom of the slide.” Id. at ¶ 23. Consequently, Plaintiff entered the slide as instructed, “and upon reaching the bottom (shutdown lane) of the slide,” Plaintiff “was not sufficiently slowed down, causing Plaintiff’s feet to violently strike the end of the waterslide shutdown lane.” Id. Plaintiff now contends that Carnival crewmembers were negligent by failing “to exercise reasonable care for the safety of C[arnival] passengers including the Plaintiff.” Id. at ¶ 25. Plaintiff claims the employees breached their duty of care by either (1) failing “to monitor the water so as to allow safe ingress and egress from the slide;” (2) failing “to monitor the water levels of the slide and shutdown lane;” (3) failing “to warn the Plaintiff of the presence of the hazardous or dangerous condition of the waterslide;” (4) failing to correct “the improper water levels in the waterslide and shutdown lane before Plaintiff used the slide;” (5) failing “to implement and/or follow and/or enforce policies and procedures regulating safe slide use and operation; or (6) [i]nstructing Plaintiff to use the waterslide when it was unsafe to do so.” ECF No. [1] at ¶ 26. Plaintiff maintains that

since the negligent conduct was all done by Carnival crew members in furtherance of the ship’s business, Carnival “is vicariously liable for their failure to exercise reasonable care and consequent negligence.” Id. at ¶ 27. Plaintiff also contends Carnival is directly liable for his injuries. See id. at ¶¶ 29-40. According to Plaintiff, Carnival “knew of the dangerous condition [that] occurs when proper water levels are not maintained in the slide and shutdown lane” as evidenced by Carnival’s internal policies and its decision to station crew members on the water slide to monitor and control water levels. Id. at ¶ 31. Furthermore, Plaintiff asserts that Carnival “also knew of the dangerous condition because it has had many incidents in the past in which passengers were injured when proper levels were not monitored and/or maintained in the waterslide and shutdown lane.” Id. at ¶

32. Carnival now seeks dismissal of the Complaint, contending that Plaintiff has failed to adequately allege either a vicarious liability or a direct negligence claim. See ECF No. [5]. Carnival argues that both counts fail to state a claim upon which relief may be granted because Plaintiff fails to sufficiently allege that Carnival had actual or constructive notice of the dangerous condition. See id. at 4. Plaintiff responds that he has properly asserted a claim of vicarious liability because there is no notice requirement for a vicarious liability claim and he has sufficiently identified the negligent employees who caused his injuries. See ECF No. [7]. Regarding his direct negligence claim, Plaintiff contends he has adequately alleged actual notice of the waterslide’s dangerous condition given that there were Carnival employees stationed at the top and bottom of the slide who, under Carnival’s policies, were responsible for ensuring that the slide maintained an adequate water level. See id. at 4-5.

II. LEGAL STANDARD A. Failure to State a Claim A pleading must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Although a complaint “does not need detailed factual allegations,” it must provide “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007); see Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (explaining that Rule 8(a)(2)’s pleading standard “demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation”). Additionally, a complaint may not rest on “‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 557, 127 S. Ct. 1955).

“Factual allegations must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555, 127 S. Ct. 1955. If the allegations satisfy the elements of the claims asserted, a defendant’s motion to dismiss must be denied. See id. at 556. When reviewing a motion to dismiss, a court, as a general rule, must accept the plaintiff’s allegations as true and evaluate all plausible inferences derived from those facts in favor of the plaintiff. See Chaparro v. Carnival Corp., 693 F.3d 1333, 1337 (11th Cir. 2012); Miccosukee Tribe of Indians of Fla. v. S. Everglades Restoration Alliance, 304 F.3d 1076, 1084 (11th Cir.

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Riffle v. Carnival Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riffle-v-carnival-corporation-flsd-2025.