Floating homes as boats
Lozman v. The City of Riviera Beach
In brief
The Supreme Court overturned the Eleventh Circuit and ruled that Lozman’s floating home was not a vessel under federal law.
- Where it stands
- Decided
Decided 7-2 · January 15, 2013 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court ruled that Fane Lozman’s floating home was not a vessel under federal law and overturned the Eleventh Circuit.
- Who it affects
- The ruling means Lozman’s floating home did not count as a vessel under the federal law at issue.
Summary: written with AI from the case record.
What it's about
It also said the dispute remained live after Riviera Beach bought and destroyed the home because a court-ordered bond could preserve Lozman’s chance to obtain money if he prevailed.
The dispute asked whether a floating home moored indefinitely and supplied from shore qualified as a vessel, which would bring the case within federal maritime jurisdiction.
Question presented
Is a floating structure a "vessel" under 1 U.S.C. § 3, thus triggering federal maritime jurisdiction, if that structure is indefinitely moored, receives power and other utilities from shore, and is not intended to be used in maritime transportation or commerce?
What the Court decided
Holding
This case is not moot. The District Court ordered the floating home sold, and the City purchased the home at auction and had it destroyed. Before the sale, the court ordered the City to post a bond to ensure Lozman could obtain monetary relief if he prevailed. Lozman’s floating home is not a §3 “vessel.” 649 F. 3d 1259, reversed.
- Result
- Reversed
The vote
From the opinions
“Given the underdeveloped record below, we should remand.”
What's next
The Supreme Court resolved the vessel question for Lozman’s home. The decision does not state a further step for the City or lower courts.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
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Audio Recording added: Oral Arguments - Lozman
Opinion added: Lozman
More questions
- What did Justice Sotomayor say should happen?
- She said the record was underdeveloped and the case should be sent back for more proceedings.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.