## Facts

- In September 2005, Kyles Carpenter took a pleasure cruise on the *Miracle*, a vessel owned and operated by Carnival Corporation.
- During the cruise, Carpenter played slot machines in the *Miracle*’s casino room and alleged he won a cash jackpot.
- Carpenter also alleged he won 3,355,443 “bonus points,” allegedly worth a substantial reward.
- According to Carpenter, immediately after the win, Carnival employees opened the slot machine, erased the award, and returned Carpenter’s original wager.
- The employees allegedly told Carpenter he was not entitled to the cash jackpot or the bonus points.
- Carpenter sued Carnival in federal district court in Florida asserting claims for breach of implied contract, unjust enrichment, fraud, fraudulent misrepresentation, and conversion.
- Carpenter alleged that Carnival’s marketing materials advertising casino-style gambling onboard induced him to enter into a cruise-line passage contract with Carnival.
- Carnival moved to dismiss the complaint, and the district court analyzed whether it had admiralty jurisdiction over Carpenter’s claims.

## Issues

1. Whether a passenger’s claims arising from an alleged refusal to pay cruise-ship slot-machine winnings and related bonus points fall within federal admiralty jurisdiction.
2. Whether the relationship between the alleged casino conduct and the passenger’s voyage supplies a sufficient maritime connection to support admiralty subject-matter jurisdiction.

## Decision

- The district court, addressing Carnival’s motion to dismiss, treated admiralty jurisdiction as a threshold issue and analyzed whether Carpenter’s onboard casino-winnings dispute could be heard in admiralty.
- The court’s analysis focused on whether the alleged conduct and resulting claims were sufficiently maritime in nature to invoke federal admiralty jurisdiction.

## Legal Principles

- Federal admiralty jurisdiction is limited; the court must determine whether the asserted claims are maritime in nature before proceeding under admiralty.
- In assessing admiralty jurisdiction over passenger-related incidents occurring aboard a vessel during a voyage, courts evaluate whether the dispute bears the required maritime relationship (including the location of the events and their connection to maritime activity).
- The existence of a passenger-carriage relationship and the fact that conduct occurred aboard a cruise vessel during a voyage are relevant considerations in determining whether admiralty jurisdiction applies.

## Conclusion

*Carpenter v. Carnival Corp.* involves a cruise passenger’s allegation that the ship’s casino voided a slot-machine jackpot and millions of bonus points. On Carnival’s motion to dismiss, the district court considered whether the dispute qualified for federal admiralty jurisdiction based on the maritime character of the alleged onboard events and their relationship to the passenger’s cruise.


Carpenter v. Carnival Corp., 2007 WL 9702036 (2007)