## Facts

- In July 2000, Raymond Ashman IV piloted a boat with Brendan Murphy and Steven Murphy during lobster mini-season in the Florida Keys.
- The boat struck an electric pole abutment support structure owned by Florida Keys Electric Cooperative Association, Inc.
- Brendan Murphy was killed; Steven Murphy and Raymond Ashman IV were injured.
- Brendan and Steven’s parents sued the Cooperative in federal court under admiralty jurisdiction for wrongful death and personal injury; they did not sue the Ashmans.
- The Cooperative filed a third-party claim against the Ashmans seeking contribution or indemnity, alleging their fault contributed to the accident.
- The Ashmans filed a counterclaim against the Cooperative for Raymond Ashman IV’s injuries, relying on supplemental jurisdiction.
- The Cooperative settled with the Murphys, but the settlement did not release the Ashmans from potential liability to the Murphys.
- The Ashmans sought summary judgment on the Cooperative’s contribution claim, arguing that failure to obtain a release barred contribution under admiralty settlement-allocation rules.

## Issues

1. Whether a settling defendant in an admiralty tort action that does not obtain a release for other potential tortfeasors may later recover contribution from them for the settlement payment.
2. Whether the district court properly dismissed a counterclaim supported only by supplemental jurisdiction after the admiralty claim was resolved by settlement.

## Decision

- The Eleventh Circuit affirmed summary judgment for the Ashmans on the Cooperative’s contribution claim.
- Applying the proportionate-share approach to admiralty settlements, the court held that a settling defendant that fails to secure a release for nonsettling tortfeasors cannot pursue contribution against them.
- The Eleventh Circuit also affirmed dismissal without prejudice of the Ashmans’ counterclaim, holding the district court acted within its discretion in declining supplemental jurisdiction once the admiralty anchor claim ended.

## Legal Principles

- In admiralty, the proportionate-share approach allocates damages among joint tortfeasors so that nonsettling defendants are responsible only for their adjudicated share, and settlements reduce the plaintiff’s recovery by the settling defendant’s share.
- A settling defendant that does not obtain a release for other potential tortfeasors is treated as settling only its own proportionate share and cannot shift settlement costs to nonsettling parties through a contribution action.
- A federal court may decline supplemental jurisdiction over remaining state-law claims after the claim supplying original federal jurisdiction has been resolved, and dismissal without prejudice is an appropriate disposition.

## Conclusion

The Eleventh Circuit held that admiralty’s proportionate-share settlement framework bars contribution claims by a settling defendant that did not obtain a release for other potential tortfeasors, and it approved dismissal without prejudice of a counterclaim resting solely on supplemental jurisdiction after settlement ended the admiralty claim.


Murphy v. Fla. Keys Elec. Coop. Ass’n, 329 F.3d 1311 (11th Cir. 2003)