In Northern Queen, Inc. v. Kinnear, 2002 WL 1799711 (9th Cir. August 7, 2002), the U.S. Ninth Circuit Court of Appeals held that Blake Kinnear, master (and 22 percent owner) of the F/V LIN J, violated the primary duty rule when the vessel sank in icy waters of the Bering Sea in March 1999, relieving the vessel's owner, Northern Queen, Inc.--77 percent owned by his wife and one percent owned by his minor daughter--of liability for his death. Northern Queen initiated the suit by filing a claim under the Limitation of Liability Act, seeking to limit the vessel owner's liability to the post-casualty value of the vessel together with her pending freight.
