Justia U.S. 5th Circuit Court of Appeals Opinion Summaries

This case arose from an oil spill in the Mississippi River when an ocean-going tanker struck a barge that was being towed. Appellants (Excess Insurers) appealed the district court's decision requiring them to pay prejudgment interest on the funds deposited into the court's registry in an interpleader action. The Excess Insurers argued that the district court erred by: (1) finding that coverage under the excess policy was triggered by the primary insurer's filing of an interpleader complaint; (2) holding that a marine insurer that filed an interpleader action and deposited the policy limits with the court was obligated to pay legal interest in excess of the policy limits; and (3) applying the incorrect interest rate and awarding interest from the incorrect date. The court held that because the Excess Insurers' liability had not been triggered at the time the Excess Insurers filed their interpleader complaint, the district court erred in finding that they unreasonably delayed in depositing the policy limit into the court's registry and holding them liable for prejudgment interest. Therefore, the court reversed the judgment and did not reach the remaining issues.

This case stemmed from the transportation excise tax that National Airlines (National) owed the government. Plaintiff appealed the district court's summary judgment determination that, pursuant to 26 U.S.C. 6672, he was personally liable for the excise taxes that National collected from its passengers but failed to pay over to the United States during his tenure as National's CEO. The court affirmed the judgment of the district court and held that the district court properly found that plaintiff was a "responsible person" and that his failure to pay taxes was willful as defined by this circuit's precedents.

QT Trading, L.P. ("QT") sued defendants for rust damage to its steel pipes that allegedly occurred during their transport from Dalian, China to Houston, Texas. At issue was whether the district court properly granted summary judgment to in personam defendants on QT's claims for damages under the Carriage of Goods at Sea Act ("COGSA"), 46 U.S.C. 30701 note (Carriage of Goods by Sea), and for negligent bailment of its goods. The court affirmed summary judgment and held that the district court properly dismissed QT's COGSA claims where QT failed to establish genuine issues of material fact where none of the defendants were "carriers" and thus could not be liable for damages under the statute. The court also held that the district court properly dismissed QT's bailment claims where QT failed to show that a certain defendant had exclusive possession of the cargo.