Folksamerica Reinsurance Co. Ex Rel. Christiana General Insurance Co. of New York v. Clean Water of New York, Inc.
Folksamerica Reinsurance Company, as successor to Christiana General Insurance Company, sought a declaratory judgment against Clean Water of New York, Inc., seeking to be relieved of its obligation to defend or indemnify Clean Water in a personal injury lawsuit. The underlying suit stemmed from an injury sustained by Milton Rivera while cleaning an ocean-going vessel in New York Harbor. The central legal question for the federal court was whether it possessed admiralty jurisdiction, which hinged on whether the insurance policy was a 'maritime' contract. The court concluded that the primary Section I of the policy, a comprehensive general liability section, lacked maritime character, and the policy as a whole was not purely maritime. Consequently, as the claim did not arise under the potentially maritime Section II, and exceptions for mixed contracts did not apply, the court dismissed the complaint for lack of subject matter jurisdiction.