Golden Eye 2000, LLC

Background

Golden Eye 2000, LLC brought an admiralty action under the Limitation of Liability Act and Supplemental Admiralty and Maritime Claims Rule F. The action concerned losses, injuries, and damages allegedly arising from an incident aboard the Golden Eye vessel on or around December 15, 2018.

The court found that Golden Eye had complied with Rule F’s notice requirements. Golden Eye published notice in the San Francisco Daily Journal stating that potential claimants had to file claims or answers by July 22, 2019. Vitaliy Peshko filed an answer and claim on July 19, 2019. No other claimant filed an answer or claim, and the clerk entered default against all nonappearing claimants on September 25, 2019.

Default Judgment

The court explained that default judgment is discretionary and that, after default is entered, the complaint’s factual allegations generally are treated as true except allegations about damages. In Rule F cases, a court may enter default judgment against potential claimants who do not respond to the required public notice.

Because Golden Eye complied with the notice requirements and no claimant other than Mr. Peshko filed a claim or answer, the court granted Golden Eye’s motion for default judgment against nonappearing claimants. The court confirmed and entered the default of people who failed to file claims by the court-ordered deadline, barred and permanently restrained those people from filing or pursuing claims that should have been filed in the limitation proceeding, and entered judgment exonerating Golden Eye from liability for future claims arising from the December 15, 2018 events involving the vessel.

Remand and Stay

The parties jointly asked the court to remand the case to Alameda County Superior Court and stay the federal proceeding. The court applied the “single claimant exception,” which allows a claimant to pursue the claim in state court when only one claim has been filed and the vessel owner’s right to seek limitation of liability is protected.

The court found that the parties made the required stipulations: Mr. Peshko was the sole claimant; the $500,000 limitation fund equaled the value of Golden Eye’s interest in the vessel; the parties waived reliance on claim-preclusion principles based on decisions outside the federal limitation proceeding; and Mr. Peshko conceded the federal court’s exclusive authority to decide limitation-of-liability issues.

The court therefore dissolved the injunction against related state-court proceedings and granted the parties’ joint stipulation to remand and stay the case. Judge Haywood S. Gilliam, Jr. ordered the case remanded to the California Superior Court for Alameda County, stayed the federal case, required joint status reports every 180 days, and directed the clerk to remand the case and administratively close the federal file.