United States v. Ships Int'l Inc

District Court, W.D. Washington·Decided July 28, 2025·No. 2:23-cv-01677·Unknown

Opinion

1 2 3

4 WESTERN DISTRICT OF WASHINGTON 7 UNITED STATES OF AMERICA, 8 Plaintiff, 9 v. C23-1677 TSZ 10 SHIPS INT’L INC., FELIX VERA, THE ESTATE OF CHRISTIAN ORDER 11 LINT, and MARINE SERVICES INT’L INC., 12 Defendants. 13

14 THIS MATTER comes before the Court on the United States’ motion for 15 summary judgment (the “Motion”), docket no. 66. Having reviewed the Motion, the 16 Court enters the following order. 17 I. Background 18 The Court has previously set forth the undisputed material facts relevant to this 19 matter. See Order (docket no. 65). In that order, the Court denied the motion for summary 20 judgment filed by defendant the Estate of Christian Lint (the “Estate”) and concluded that 21 Mr. Lint is a “responsible party” under the Oil Pollution Act of 1990 (“OPA”), 33 U.S.C. 22 §§ 2701–2720. See id. at 6 (docket no. 65). The United States now moves for summary 1 judgment against all defendants. See Motion (docket no. 66). The Court scheduled for 2 July 1, 2025 oral argument on the Motion, and the related motion to strike1, docket 3 no. 73. At the hearing, counsel for Mr. Vera and MSI advised the Court that Mr. Vera had

4 filed a personal bankruptcy complaint under Chapter 7 with the United States Bankruptcy 5 Court in the Southern District of Florida, case number 9:25-bk-17576-MAM. As a result, 6 the Court stayed the case as to Mr. Vera, and as to Ships and MSI, see Minute Entry 7 (docket no. 83), because the record reflects that Mr. Vera is the sole owner of those 8 entities.

9 The Court orally granted summary judgment in favor of the United States as to the 10 Estate, holding that Mr. Lint is strictly liable under the OPA for the grounding of the M/V 11 American Challenger, including all removal costs and damages incurred by the 12 government. See Minute Entry (docket no. 83). The Court stated that it would enter an 13 order on the Motion following the hearing. Id.

14 II. Discussion 15 a. Summary Judgment Standard 16 The Court shall grant summary judgment if no genuine issue of material fact exists 17 and the moving party is entitled to judgment as a matter of law. Federal Rule of Civil 18 Procedure 56(a). The moving party bears the initial burden of demonstrating the absence

19 of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). A 20

21 1 Because the case is stayed with respect to Mr. Vera, Ships, and MSI, see Minute Entry (docket no. 83), 22 the motion to strike is DEFERRED until the stay is lifted. 1 fact is material if it might affect the outcome of the suit under the governing law. 2 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To survive a motion for 3 summary judgment, the adverse party must present affirmative evidence, which “is to be

4 believed” and from which all “justifiable inferences” are to be favorably drawn. Id. at 5 255, 257. When the record, however, taken as a whole, could not lead a rational trier of 6 fact to find for the non-moving party, summary judgment is warranted. See Beard v. 7 Banks, 548 U.S. 521, 529 (2006) (“Rule 56 ‘mandates the entry of summary judgment, 8 after adequate time for discovery and upon motion, against a party who fails to make a

9 showing sufficient to establish the existence of an element essential to that party’s case, 10 and on which that party will bear the burden of proof at trial.’” (quoting Celotex, 477 11 U.S. at 322)). 12 b. Prima Facie Liability Under the OPA 13 Under the OPA, responsible parties for a vessel or facility from which oil is

14 discharged, or from which there is a substantial threat of discharge, are strictly liable for 15 resulting damages, subject to certain exceptions. 33 U.S.C. § 2702(a); Clausen v. M/V 16 New Carissa, 339 F.3d 1049, 1052 (9th Cir. 2003); United States v. Kilroy & Assocs., 17 Inc., 2009 WL 3633891, at *4 (W.D. Wash. Oct. 30, 2009). 18 To establish strict liability, the government must prove: (1) that the defendant is a

19 “responsible party”; (2) that oil was discharged or that the incident posed a substantial 20 threat of discharge; and (3) that the actual or threatened discharge occurred in navigable 21 waters or adjoining shorelines. 33 U.S.C. § 2702(a). If these elements are satisfied, the 22 government has established a prima facie case. 1 i. Responsible Party 2 Under the OPA, a “responsible party” is “any person owning, operating, or demise 3 chartering a vessel.” 33 U.S.C. § 2701(32)(A). An “owner or operator” is, “in the case of

4 a vessel, any person owning, operating, or chartering by demise, the vessel.” 33 U.S.C. 5 § 2701(26)(A)(i). A “person” under the OPA can be an individual or a corporation. See 6 33 U.S.C. § 2701(27). Further, a “vessel” “means every description of watercraft or other 7 artificial contrivance used, or capable of being used, as a means of transportation of 8 water, other than a public vessel.” 33 U.S.C. § 2701(37). “Operator” 2 includes those

9 “persons” who “manage, direct, or conduct operations specifically related to pollution.” 10 United States v. Bestfoods, 524 U.S. 51, 67 (1998). 11 This Court has already held that Mr. Lint is a “responsible party” within the 12 meaning of the OPA. See Order at 6 (docket no. 65). 13 ii. Actual or Substantial Threat of Discharge of Oil

14 With respect to the second element, strict liability under the OPA is triggered by 15 either the “discharge” of oil, or the “substantial threat of discharge” of oil. See 33 U.S.C. 16 § 2702(a); see also Kilroy, 2009 WL 3633891, at *4. Following the grounding of the 17 M/V American Challenger, approximately 50 gallons of oil were discharged into the 18

19 2 The Bestfoods court interpreted the Comprehensive Environmental Response, Compensation, and 20 Liability Act of 1980 (“CERCLA”). See United States v. Bestfoods, 524 U.S. 51 (1998). This statute, which preceded the OPA, is “a statute to which courts frequently look when interpreting the OPA [and which] broadly extends liability all the way down the causal chain.” United States v. Bros. Enterprises, 21 Inc., 113 F. Supp. 3d 907, 913 (E.D. Tex. 2015) (internal quotation marks omitted). Accordingly, the Court looks to cases where courts interpreted CERCLA to interpret the OPA and reads the OPA’s 22 “responsible party” language broadly. 1 water, oil sheening surrounding the vessel was observed, and oil and hazardous materials 2 were found on board. Macon Decl. at ¶¶ 9, 11, 12 (docket no. 68).

Free access — add to your briefcase to read the full text and ask questions with AI

United States v. Ships Int'l Inc, (W.D. Wash. 2025).

United States v. Ships Int'l Inc (United States v. Ships Int'l Inc) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
United States v. Bestfoods
524 U.S. 51 (Supreme Court, 1998)
Beard v. Banks
548 U.S. 521 (Supreme Court, 2006)
Simon, II v. Navon
71 F.3d 9 (First Circuit, 1995)
Savage Services Corporation v. United States
25 F.4th 925 (Eleventh Circuit, 2022)
United States v. Brothers Enterprises, Inc.
113 F. Supp. 3d 907 (E.D. Texas, 2015)
Clausen v. M/V New Carissa
339 F.3d 1049 (Ninth Circuit, 2003)