McBride v. The Stillwater Yacht Club

Background

Charles McBride and Mulroy Bay, LLC brought an action under the federal vessel-liability limitation statute, 46 U.S.C. §§ 30501 et seq., concerning the grounding, attempted salvage, and loss of the M/V EMERALD C. The plaintiffs sought exoneration from liability or limitation of liability. The court considered their “Ad Interim Stipulation,” which requested a limitation fund, a notice of monition, and an order temporarily stopping other proceedings involving the plaintiffs, the vessel, or related property.

Court’s analysis

The court explained that the limitation statute can allow a vessel owner to limit liability to the value of the vessel and pending freight when the loss occurred without the owner’s “privity or knowledge.” Before issuing the requested notice and injunction, the court had to determine whether the plaintiffs satisfied the filing and security requirements in 46 U.S.C. § 30511(b) and Supplemental Admiralty and Maritime Claims Rule F(1).

The court found that the plaintiffs filed their verified complaint on September 25, 2025. The complaint alleged that the vessel grounded on March 26, 2025, and that McBride received invoices from parties claiming payment for salvage-related services. The court concluded that the filing satisfied the six-month requirement for claims made in the days following the grounding. The plaintiffs stated that the vessel was a total loss, that nothing of value was saved, and that the total value of their interest in the vessel and pending freight was zero dollars.

Order

The court approved a limitation fund of $1,000 under the plaintiffs’ stipulation and the district’s Admiralty and Maritime Local Rules. The court stated that the amount could be challenged by future parties or revised in the interests of justice.

The court granted the plaintiffs’ request for a notice of monition. It ordered publication of the notice once per week for four successive weeks in The Monterey County Herald, The Carmel Pine Cone, and The Mercury News, beginning no later than October 20, 2025. By the date of the second publication, the plaintiffs were required to mail the notice to every person known to have made a claim arising from the March 26, 2025 grounding.

The court also temporarily restrained and enjoined further prosecution of claims, actions, or proceedings against the plaintiffs or their property relating to the grounding until March 20, 2026. After the final parties were determined, the court stated that it could permanently enjoin such proceedings if those parties consented. The order addressed the limitation-action procedures and temporary protection; it did not resolve the underlying liability claims.