State Enjoined From Administrative Proceeding Against Operator of Vessel

Matter of Complaint of Marcotte, No. CV 25-173MRD, 2025 WL 2506130 (D.R.I. Sept. 2, 2025).

By Arthur A. Crais, Adjunct Professor of Law

After a collision of two vessels in the state waters of Rhode Island, Ryan and Brenda Marcotte filed for Limitation of Liability in federal court and sought an injunction against any parties and to file claims in the concursus.[1] Two individuals in one vessel filed suit in state court against Marcotte for personal injuries. The Rhode Island Department of Environmental Management (“RIDEM”) also charged Ryan Marcotte for civil violations of the Rhode Island navigational rules in the state traffic tribunal. All proceedings were enjoined.[2]

            The state administrative proceedings would expose Ryan Marcotte to a maximum fine of $400.[3] RIDEM filed a Motion to Lift the Stay allowing it to proceed in the civil administration proceedings.

            Relying on Matter of Grace Ocean Priv. Ltd.,[4] the court determined that the findings of the civil administrative proceeding are “inextricably intertwined with the factual issues” to be determined in the limitation proceeding.[5] This would “undermine” the admiralty jurisdiction of the court and lead to potential inconsistencies. Thus, the magistrate recommended that the district court deny the Motion to Lift the Stay.

            A copy of the opinion is attached.[6]

[1] 2025 WL 2506130 at *1.

[2] Id. at *2.

[3] Id.

[4] Matter of Grace Ocean Priv. Ltd., No. CV JKB-24-0941, 2025 WL 2483227, 461, 468–69 (D. Md. Aug. 28, 2025) (involving the allision of M/V DALI with the Francis Scott Key Bridge in Baltimore, Md.).

[5] 2025 WL 2506130 at *3.

[6] Id.