Catlin Syndicated Limited v. Ramuji, LLC et al

On August 18, 2017, the U.S. Court of Appeals for the Eleventh Circuit affirmed summary judgment in Catlin Syndicated Limited v. Ramuji, LLC, a marine insurance dispute. Ramuji, LLC owned the yacht M/Y Ramuji, insured by Catlin under a policy containing a navigational warranty that restricted use to Florida waters. The yacht ran aground in the Florida Keys while on a voyage intended for the Bahamas. Catlin denied coverage, asserting that the intended voyage breached the warranty. The district court agreed, and the Eleventh Circuit upheld the decision, ruling that the warranty was unambiguous and strictly construed; even if the casualty occurred near Florida, the planned voyage outside covered waters voided the policy. The case exemplifies the strict application of insurance warranties in admiralty.

Summary judgment for the insurer affirmed; the policy was void due to breach of warranty, and no coverage was owed for the loss.

Whether the insured’s intended voyage to the Bahamas breached the policy’s navigational warranty limiting use to Florida waters, and whether such breach voided coverage regardless of where the casualty occurred.

The ruling reinforced the strict construction of warranties in marine insurance law, emphasizing that any deviation from a navigational warranty can forfeit coverage. It underscored the importance of precise policy language and heightened underwriting scrutiny for maritime operators.