## Facts

- Harrah’s Illinois Corp. owned and operated a riverboat casino located on a navigable portion of the Des Plaines River in Illinois.
- At the time of the incident, the casino boat had been moored to a pier attached to land for about two years.
- Illinois law allowed casino boats to remain moored indefinitely.
- Lucille Tagliere, a patron, was playing a slot machine and leaning against a stool when the stool collapsed.
- Tagliere fell and suffered injuries.
- The boat was stationary; the incident did not involve vessel motion, river conditions, or any accident affecting other traffic on the river.
- Tagliere filed suit in federal district court and invoked admiralty jurisdiction, seeking to proceed under maritime law.
- Harrah’s moved to dismiss for lack of subject-matter jurisdiction, arguing the claim was essentially land-based premises liability because the boat was effectively permanent in place.
- The district court granted the motion and dismissed the case.
- Tagliere appealed to the Seventh Circuit.

## Issues

1. Whether a patron’s personal-injury claim arising from a collapsed stool inside a riverboat casino moored long-term to a pier, but afloat on navigable waters, falls within federal admiralty tort jurisdiction.
2. Whether an indefinitely moored casino boat should be treated as the equivalent of land for admiralty-jurisdiction purposes.

## Decision

- The Seventh Circuit reversed the dismissal and remanded for further proceedings.
- The court held the case fell within federal admiralty jurisdiction because the injury occurred on a vessel afloat on navigable waters.
- The court rejected the district court’s “functional land” approach to an indefinitely moored casino boat, reasoning that current Supreme Court doctrine did not authorize carving out that exception.
- The court recognized the accident looked like ordinary premises liability and had no meaningful link to maritime risks, but concluded jurisdiction turns on administrable doctrinal tests rather than a case-by-case judgment about how “boat-like” a floating casino is.

## Legal Principles

- Admiralty tort jurisdiction generally requires both (1) a location element (the tort occurs on navigable waters, or a vessel on navigable waters causes injury on land) and (2) a connection element tied to maritime activity, as described in Supreme Court decisions addressing modern admiralty tort jurisdiction.
- For the location element, an injury occurring on a vessel afloat on navigable waters satisfies the situs requirement even if the vessel has been moored to a pier for an extended period and used much like a building.
- Lower courts should not create extra jurisdictional carve-outs—such as treating a long-term moored vessel as “land”—unless supported by controlling Supreme Court authority; jurisdictional rules favor clarity and workable lines over fact-intensive “how land-like is it” inquiries.
- The absence of a strong maritime flavor in the instrumentality of injury (a stool) or the immediate cause of harm does not, by itself, defeat admiralty jurisdiction when the governing tests are otherwise met.
- A court may think state tort law would fit the dispute better on the merits, but the desirability of one body of law over another does not control subject-matter jurisdiction.

## Conclusion

Because Tagliere’s injury occurred on a casino boat that was afloat on a navigable river, the Seventh Circuit held the claim fit within federal admiralty jurisdiction even though the boat was moored long-term and the accident resembled a typical land-based premises-liability case; the court reversed the jurisdictional dismissal and returned the case to the district court.


Tagliere v. Harrah's Illinois Corp., 445 F.3d 1012, 2006 AMC 1290 (2006)