## Facts

- Debra S. Lynch alleged she suffered personal injuries while a passenger in an 18-foot recreational speedboat on Lake Cumberland, Kentucky.
- The boat was owned by Charles L. McFarland and operated by Betty J. McFarland at the time of the accident.
- Lynch sued the McFarlands in federal court for negligence and invoked admiralty jurisdiction.
- A magistrate judge recommended exercising admiralty jurisdiction; the district court adopted that recommendation in an order entered without considering defendants’ objections.
- Defendants moved under Federal Rule of Civil Procedure 60 to set aside the order; the district court reconsidered the jurisdiction question de novo.
- The central jurisdictional dispute was whether Lake Cumberland constitutes “navigable waters” for admiralty purposes.
- Evidence included testimony from a U.S. Army Corps of Engineers employee stating that vessels could not navigate out of Lake Cumberland, despite its connection to the Cumberland River system through the Big South Fork.

## Issues

1. Whether the court should grant Rule 60 relief from its prior order adopting the magistrate judge’s recommendation without considering defendants’ objections.
2. Whether a recreational boating tort occurring on Lake Cumberland falls within federal admiralty jurisdiction, including whether Lake Cumberland is “navigable waters” in the admiralty sense.

## Decision

- The court reconsidered the magistrate judge’s recommendation de novo in light of defendants’ objections.
- The court declined to set aside its prior jurisdictional ruling and maintained admiralty jurisdiction.
- The court held that the boating accident satisfied the maritime-activity nexus for admiralty tort jurisdiction.
- The court held that Lake Cumberland qualifies as navigable waters for admiralty purposes because it is sufficiently connected to an interstate water system capable of serving as a channel of commerce.

## Legal Principles

- Admiralty tort jurisdiction requires (1) a tort occurring on navigable waters and (2) a significant relationship to traditional maritime activity.
- Negligent operation of a vessel on navigable waters, including in recreational boating, ordinarily satisfies the traditional maritime activity requirement.
- Waters are navigable for admiralty purposes if, in their ordinary condition, they form by themselves or by connection with other waters a continued highway over which commerce is or may be carried on with other states or foreign countries.
- Man-made obstructions or improvements (such as dams) do not automatically defeat navigability if the water body, viewed as part of a larger connected system, is used or is susceptible to use as a channel of interstate commerce.
- When a court’s adoption of a magistrate judge’s recommendation occurs without consideration of objections, the court may cure the defect by conducting de novo review rather than automatically vacating the prior ruling.

## Conclusion

After de novo review prompted by defendants’ Rule 60 motion, the court continued to exercise admiralty jurisdiction, concluding that Lake Cumberland is navigable for admiralty purposes and that a recreational boating accident on the lake bears a sufficient relationship to traditional maritime activity.


Lynch v. McFarland, 808 F. Supp. 559 (W.D. Ky. 1992)