Recreational Boats: the Evolution of Jurisdiction and Choice-of-Law Issues From the Constitution Through the Calhoun Decisions

Jurisdiction and choice-of-law issues have been the subjects of many of the seminal cases of admiralty jurisprudence. Recently, perhaps because they “push the envelope” of these issues, decisions invoking recreational boats have been on the cusp of this jurisprudence--defining the limits of substantive admiralty law. This Article will address and analyze the development of admiralty jurisdiction and the application of substantive admiralty law generally--but also will be specifically directed to the developments effected by decisions involving recreational boats. Particular attention will be paid to the Supreme Court and Third Circuit decisions in Calhoun v. Yamaha Motor Corp., U.S.A.