i-law

Lloyd's Maritime Law Newsletter

Sea Byte Inc v Hudson Marine Management Services Inc – US Court of Appeals (11th Circuit) (Barkett and Fay Ct JJ and Trager DJ) – 20 April 2009

Contract – Coral reef damaged by vessel – P&I Club entering into lump sum contract with marine environmental company to repair damage to reef – Contract containing provision for automatic termination in event of severe weather – Whether contract terminated automatically – Whether P&I Club in breach of contract – Quantum of damages and of quantum meruit

On 26 March 2004 the vessel Eastwind ran aground on an underwater coral reef just off the Fort Lauderdale coast. The vessel’s P&I Club (Miller) arranged for Hudson Marine Management Services Inc, a “marine environmental casualty management corporation” to restore the grounding site. Miller and Hudson entered into a “Time and Materials” contract for the restoration of the reef. Hudson was to be compensated on a time and materials basis at specified rates, plus reimbursement for specified expenses at cost plus 15%. Hudson subcontracted with Sea Byte Inc to carry out the restoration work.

The rest of this document is only available to i-law.com online subscribers.

If you are already a subscriber, click Log In button.

Copyright © 2025 Maritime Insights & Intelligence Limited. Maritime Insights & Intelligence Limited is registered in England and Wales with company number 13831625 and address 5th Floor, 10 St Bride Street, London, EC4A 4AD, United Kingdom. Lloyd's List Intelligence is a trading name of Maritime Insights & Intelligence Limited.

Lloyd's is the registered trademark of the Society Incorporated by the Lloyd's Act 1871 by the name of Lloyd's.