Interesting case noting the interplay between the Declaratory Judgment Act and the federal courts' admiralty jurisdiction. The case is Garanti Finansal Kiralama A.S. v. Aqua Marine and Trading, Inc. and the original opinion can be found here.
Facts are straightforward: a marine shipping fuel provider brought a claim in arbitration demanding to be paid for bunkers provided to two ships owned by Garanti. The provider submitted the "order confirmation contracts" which contained the arbitratrion provisions being invoked. The shipowner filed an admiralty complaint in federal court asserting admiralty jurisdiction and seeking declaratory judgment that it was not bound by the arbitration provision because it did not sign the "order confirmation contracts". The vessels' owner advised that it had chartered the vessels under a bareboat charter to third parties and those charterers may have hired the entity that signed the contracts.
The trial court felt persuaded that the entity signing the contracts was an agent for the vessels owner and dismissed the complaint.
The Second Circuit vacated that dismissal finding that the evidence was not enough to establish an agency relationship between the contracting party and the vessels' owner.
There is an interesting civil procedure issue in this case. Technically, the vessels' owner was arguing that there weren't any contracts - so, how could the federal court have admiralty jurisdiction over a maritime non-contract? The Second Circuit, seeing perhaps a gordian knot of epic proportions - notes that if the Defendant had sued the Plaintiff, there would be unquestionable admiralty jurisdiction owing to the "order confirmation contracts" - so a mirror image, declaratory judgment suit should have admiralty jurisdiction too.
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