## Facts

- Virgil Becker and Ruby Joleen Becker were injured in a boating accident on the Ohio River near the Smithland Pool area between Kentucky and Illinois.
- Randall William Becker, the Beckers’ son, was operating the small pleasure/fishing boat; Virgil was a passenger, and Ruby asserted loss of consortium.
- The Beckers alleged that the operation of three nearby commercial tows created a surge or wave that caused their boat to capsize.
- The Beckers settled their negligence claims against Randall in March 1990 for $45,000.
- On June 22, 1992, the Beckers sued the owners/operators of the commercial vessels—Crounse Corporation, M/G Transport Services, and Mid-South Towing Company (the barge owners)—alleging negligence.
- The barge owners removed the case to federal court and filed a third-party claim/crossclaim against Randall seeking contribution if the barge owners were found liable to the Beckers.
- Randall moved to dismiss the contribution claim, arguing that his settlement with the Beckers ended any further liability related to the accident.
- The parties also disputed the basis for federal jurisdiction and whether state law or federal maritime law supplied the governing rules.

## Issues

1. Does the federal court have admiralty jurisdiction over a boating-accident tort claim arising on the Ohio River, and does federal maritime law govern the dispute?
2. Under federal maritime law, does Randall Becker’s prior settlement with the plaintiffs bar the barge owners’ contribution claim against him?

## Decision

- The court held that the case fell within admiralty tort jurisdiction because the alleged wrong occurred on navigable waters and bore a significant relationship to maritime activity.
- The court ruled that federal maritime law governed the substantive questions raised by the parties, including contribution among alleged joint tortfeasors.
- The court denied Randall Becker’s motion to dismiss, holding that his settlement with the plaintiffs did not, by itself, extinguish the barge owners’ maritime contribution claim.

## Legal Principles

- Admiralty tort jurisdiction exists when (1) the alleged wrong occurs on navigable waters and (2) the incident has a significant relationship to maritime activity.
- When a claim lies in admiralty, federal maritime law supplies the rules of decision for substantive maritime issues, including allocation of fault among alleged joint tortfeasors.
- In general maritime law, a tortfeasor’s settlement with the injured party does not automatically bar contribution claims by other alleged tortfeasors; extinguishment of contribution exposure requires a clear basis in the settlement terms or an applicable rule that grants such protection.

## Conclusion

Because the alleged boating accident occurred on the Ohio River and had the required maritime connection, the court exercised admiralty jurisdiction and applied federal maritime law; applying that law, it rejected Randall Becker’s argument that his $45,000 settlement with the plaintiffs automatically ended all related liability and allowed the barge owners’ contribution claim against him to proceed.


Becker v. Crounse Corp., 822 F. Supp. 386 (1993)