Lozman v. Riviera Beach

The test for whether a floating structure is a vessel is “[whether] a reasonable observer, looking to the home’s physical characteristics and activities, would consider it designed to a practical degree for carrying people or things over water.”

Petitioner owned a “house-like plywood structure with empty bilge space underneath to keep it afloat.” (home)(see photo). Respondent brought a federal admiralty suit in rem against the home, and Petitioner moved to dismiss for lack of admiralty jurisdiction. The district court found the home to be a “vessel” which, under the Rules of Construction Act, 1 U.S.C. §1 et seq., includes “ every description of watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water.” (1 U.S.C. §3). The Court of Appeals for the Eleventh Circuit affirmed, reasoning that the home was a “vessel” since it was capable of being used for transportation over water.

The Supreme Court held that the home was not a “vessel” for purposes of admiralty law. Noting that the Eleventh Circuit’s interpretation of the Act was too broad, the Supreme Court held that the definition of “transportation” must be applied in a practical—rather than theoretical—way. The Court rejected Respondent’s arguments that the purpose test was unworkable and that the home was actually used for transportation. After reading the language of the statute in a natural way and examining the craft’s purpose, the Court determined that classifying it as a “vessel” was inconsistent with Act’s text, precedent, and relevant purpose, and reversed.