The Fifth Circuit Court of Appeals filed a new case on Jan. 16, 2026, involving Genesis Marine, LLC's attempt to limit liability in a maritime worker injury lawsuit. The appeal centers on whether the company's petition for liability limitation was filed within the required timeframe under federal maritime law.
Brandon Darrow, a former tankerman employed on Genesis Marine's towing vessel M/V Anaconda, sustained a back injury while on the job. Following his injury, Darrow filed a tort lawsuit against Genesis Marine in Louisiana state court in December 2021, alleging that his injuries resulted from the company's negligence and operation of an unseaworthy vessel. The lawsuit sought damages for his workplace injuries.
The case took a procedural turn three years later when Genesis Marine filed a limitation lawsuit in federal court on Dec. 13, 2024. Under federal maritime law, vessel owners can petition to limit their liability to the value of the vessel itself, potentially capping damages significantly below what injured parties might otherwise recover. Genesis Marine's petition specifically sought to limit its tort liability related to Darrow's injury claims.
However, Darrow challenged the timing of Genesis Marine's limitation petition through an opposed motion for summary judgment. According to court documents, Darrow argued that the company's limitation lawsuit violated the statute of limitations established under 46 U.S.C. § 30529(a). This federal statute requires limitation petitions to be filed within six months after the vessel owner receives written notice that damages from an incident could reasonably exceed the vessel's value.
The dispute centers on when Genesis Marine received adequate notice that Darrow's potential damages might exceed the value of the M/V Anaconda and associated barges GM 1006 and GM 5040. If Darrow's argument succeeds, it could bar Genesis Marine from limiting its liability, potentially exposing the company to significantly higher damage awards.
The case represents a common tension in maritime law between protecting vessel owners through liability limitations and ensuring injured workers can recover adequate compensation. The Limitation of Liability Act, codified in federal law, dates back to the 19th century and was designed to encourage maritime commerce by limiting owners' financial exposure. However, injured maritime workers and their attorneys often challenge these limitations, particularly when they believe the timing requirements haven't been met.
The Eastern District of Louisiana previously ruled on the matter, though the specific outcome of that ruling is not detailed in the available court documents. Genesis Marine's decision to appeal suggests the district court may have ruled against the company's limitation petition, either finding it untimely or otherwise invalid.
The Fifth Circuit panel reviewing the appeal consists of Circuit Judges Smith, Stewart, and Haynes, with Judge Carl E. Stewart authoring the opinion. The court's decision will have implications for maritime employers operating in the circuit's jurisdiction, which includes Louisiana, Mississippi, and Texas—states with significant maritime industries.
Maritime workers like tankermen face inherent risks in their occupation, working with heavy machinery and hazardous materials on vessels that may operate in challenging conditions. When injuries occur, the interplay between state tort law and federal maritime law can create complex legal battles over liability and damages.
The timing requirements for limitation petitions serve as a critical procedural safeguard, ensuring that vessel owners cannot indefinitely delay their decision to seek liability limitations while injured parties pursue their claims. Courts strictly enforce these deadlines, as they balance the competing interests of maritime commerce and worker protection.
For Genesis Marine, the appeal represents an attempt to preserve the limitation option that could significantly reduce its financial exposure in Darrow's case. The company operates the M/V Anaconda as a towing vessel, likely used for pushing or pulling barges in inland waterways or coastal areas where such operations are common.
The outcome of this appeal will provide guidance to maritime employers throughout the Fifth Circuit regarding the timing of limitation petitions and the notice requirements that trigger the six-month filing deadline. It may also influence how courts interpret what constitutes adequate notice that damages could exceed vessel value.
As the case proceeds through the appellate process, both parties await a decision that could substantially impact the financial stakes of Darrow's underlying injury claim and establish precedent for similar maritime liability disputes in the region.