You're Gonna Need a Bigger Boat Part 2: US Fifth Circuit Addresses the SPVA Amendments to the Limitation of Liability Act
August 18, 2026
In 2022, Congress amended the Shipowners' Limitation of Liability Act of 1851 (the Act) to preclude certain “covered small passenger vessels” from being entitled to invoke limitation under the Act, pursuant to the Small Passenger Vessel Act (SPVA).
On August 14, 2026, the US Fifth Circuit Court of Appeals issued its first ruling interpreting that amendment in M/V MS ADALYN v. Inland Dredging Co., L.L.C. There, the court held that workers transported aboard a third-party crew boat are "passengers for hire" because their employer “indirectly” paid for their transportation. The decision has ramifications for vessel owners, operators, and maritime employers alike. Read my full analysis of the decision and its practical implications in this maritime client alert.
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