Coastal Voyages as “Ocean Going” Under New York Marine Insurance Law:
A Commentary on Parr v. Yachtinsure (5th Cir. 2025)

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I. Introduction

In Parr v. Yachtinsure, No. 25‑30134 (5th Cir. Nov. 25, 2025) (per curiam) (unpublished), the United States Court of Appeals for the Fifth Circuit affirmed dismissal of an insured’s claim for over $1.23 million in damage to a yacht, holding that New York’s statutory prohibition on “named-operator” clauses in insurance policies does not apply where the policy insures an “ocean going” vessel.

While the opinion is formally non‑precedential under Fifth Circuit Rule 47.5, it is legally significant for at least three reasons:

• It endorses and applies New York federal district court decisions that define “ocean going” vessels for purposes of New York Insurance Law by reference to policy navigational limits, not vessel type or actual use.
• It confirms that a yacht permitted to sail up to 250 miles offshore along the Atlantic and Gulf coasts and the Bahamas qualifies as “ocean going” under New York insurance law.
• It illustrates how federal courts honor parties’ contractual choice of state law in maritime insurance contracts when no “well-established, entrenched” federal maritime rule governs.

The dispute centers on whether an insured pleasure craft, the M/V AFTER PARR T, is “ocean going” for purposes of an exception in New York Insurance Law that, if triggered, allows an insurer to enforce a named-operator clause that otherwise would be invalid under state law.

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II. Background and Parties

A. The Parties and the Vessel

Plaintiff–Appellant Allan T. Parr, Jr., a Louisiana resident, owns the M/V AFTER PARR T through his company, Parr T, L.L.C. The vessel is docked in Key West, Florida. Defendant–Appellee Yachtinsure, Limited, insured the vessel under a marine insurance policy containing a choice‑of‑law provision favoring New York law, subject to federal maritime law where an entrenched rule exists.

B. The Loss and the Denied Claim

On July 3, 2023, Parr took the AFTER PARR T on a day voyage. An unseated hose clamp caused the vessel to spring a leak, resulting in substantial damage. The cost of repair was stipulated at $1,237,184.81.

Yachtinsure denied coverage. One ground for denial—critical to this appeal—was a named-operator clause requiring that the vessel be captained by a “named operator” listed in the policy. Parr conceded that he was not a named operator within the meaning of the policy and that, if the clause was enforceable, coverage would not exist.

C. The Choice-of-Law Clause

The policy’s choice-of-law clause provided, in substance, that coverage disputes were to be resolved:

• under “well-established, entrenched principles of federal maritime law” where such principles exist; and
• otherwise “according to the applicable law of the State of New York.”

This structure tracks the general approach in marine insurance law after Wilburn Boat Co. v. Fireman’s Fund Ins. Co., 348 U.S. 310 (1955): where no entrenched federal maritime rule controls, state law (here, selected by contract) fills the gap.

D. Parr’s Theory: New York Law Invalidates the Named-Operator Clause

Parr’s central legal theory rested on New York Insurance Law § 3420(e), which generally bars “named-operator only” restrictions in certain liability insurance policies. He argued:

1. Under § 3420(e), New York disallows provisions that condition coverage on a particular named operator.
2. Therefore, the named-operator clause in the yacht policy is void under New York law.
3. As a result, the insurer must provide coverage for the loss.

But New York law contains a critical carve‑out: the restriction on named-operator clauses does not apply to:

• “insurance in connection with ocean going vessels”, via Insurance Law §§ 3420(i) and 2117(b)(3)(B), as recognized in Jefferson Ins. Co. of N.Y. v. Cassella, 261 F. Supp. 2d 160 (E.D.N.Y. 2003).

Parr thus sought to escape that exception by arguing that the AFTER PARR T was not “ocean going” within the meaning of New York law because the policy limited navigation to coastal waters—specifically, within 250 miles of the eastern and Gulf coasts of the United States and the Bahamas.

E. District Court Proceedings

Yachtinsure moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that:

• Under New York law, the AFTER PARR T was an “ocean going” vessel because its policy allowed substantial operations on the Atlantic Ocean and Gulf of Mexico, up to 250 miles offshore from Maine to Texas and in the Bahamas (excluding Cuba).
• Accordingly, the policy fell into the statutory “ocean going vessel” exception to § 3420(e), rendering the named-operator clause enforceable.

The district court agreed, holding that the vessel was “ocean going” under New York law because the policy’s geographical limits placed it in the North Atlantic Ocean and associated coastal waters. With the named-operator clause enforceable, Parr’s claim for coverage failed as a matter of law. The court granted the Rule 12(b)(6) motion and dismissed the suit.

Parr appealed to the Fifth Circuit.

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III. Summary of the Fifth Circuit’s Opinion

The Fifth Circuit affirmed the dismissal. Its key rulings were:

1. Standard of review. The court reviewed de novo (from scratch) both the grant of the Rule 12(b)(6) motion and the interpretation of the insurance contract. See Taylor v. Root Ins. Co., 109 F.4th 806, 808 (5th Cir. 2024).
2. “Ocean going” status is determined by the policy’s navigational or geographical limits. The court accepted Parr’s own premise that oceangoing status under New York law turns on the policy’s geographic scope, not the vessel’s design or actual use.
3. Under those limits, the AFTER PARR T is “ocean going.” Because the policy allowed navigation up to 250 miles offshore along the Atlantic and Gulf coasts and in the Bahamas, the court concluded that the vessel was plainly allowed upon the ocean and therefore “ocean going” under New York law.
4. New York’s prohibition on named-operator clauses therefore does not apply. The statutory bar in § 3420(e) is inapplicable to “insurance in connection with ocean going vessels”; thus the named-operator clause in this policy remains fully enforceable.
5. No contrary New York authority. The court found that Parr cited no persuasive New York authority undermining this conclusion. The decision he relied upon, Royal Ins. Co. of America v. A & C Ship Fueling Corp., was both distinguishable and vacated.
6. No reason to override New York law with general maritime law. The court rejected Parr’s request to fashion a competing “general maritime” definition of “oceangoing vessel,” noting the absence of any entrenched maritime rule on this point and emphasizing the parties’ contractual selection of New York law.
7. Unpreserved alternative arguments not reached. Yachtinsure advanced additional arguments (relating to the scope of § 3420(e) as to where policies are issued, where vessels are garaged, and whether the statute only governs third‑party liability coverage). The court declined to consider these arguments because they had not been presented to the district court.

On that basis, the Fifth Circuit concluded that Parr’s coverage claim was barred under the policy, and it affirmed the district court’s judgment.

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IV. Detailed Analysis

A. Precedents and Authorities Relied Upon

1. New York Federal District Court Decisions on “Ocean Going” Vessels

The Fifth Circuit’s central move was to align itself with a line of Southern and Eastern District of New York decisions treating “oceangoing” status as a function of policy territory:

• Insurance Co. of N. Am. v. Zaglool, 526 F. Supp. 2d 361 (E.D.N.Y. 2007)
  The policy limited the insured vessel to “Atlantic coastwise and inland tributary waters of the United States and Canada between St. John, New Brunswick and Morehead City, North Carolina.” The court held that, despite the coastwise limitation, the vessel was “ocean going” for purposes of the New York statutory scheme. The Fifth Circuit in Parr explicitly relied on this reasoning.
• DeGeorge v. Ace Am. Ins. Co., No. 07 Civ. 2761, 2008 WL 180786 (S.D.N.Y. Jan. 17, 2008)
  The vessel had the same navigational limitation as in Zaglool. The court likewise held it was “ocean going.” Again, the Fifth Circuit cited DeGeorge to demonstrate New York’s consistent treatment of vessels with coastwise ocean navigation permissions as “ocean going.”
• N.Y. Marine & Gen. Ins. Co. v. Travelers Prop. Cas. Co. of Am., 485 F. Supp. 3d 398 (S.D.N.Y. 2020)
  The policy used the term “coastal waters.” The court held that “coastal waters” encompass waters that are part of the ocean, and so the vessel was considered “ocean going.” The Fifth Circuit cited this case specifically for the proposition that “coastal waters” fall within the statutory oceangoing category.
• Progressive Ne. Ins. Co. v. Am. Ins. Co., No. 99 Civ. 8998, 2001 WL 959183 (S.D.N.Y. Aug. 21, 2001)
  The policy territory covered “land, tributaries, inland lakes, bays and rivers of the continental United States or Canada” and excluded “coastal waters, oceans, seas or gulfs.” There, the court held the vessel was not ocean going. The Fifth Circuit uses Progressive as the negative counterpart: policies limited to inland waters do not trigger the oceangoing exception.
• Hartford Fire Ins. Co. v. Mitlof, 123 F. Supp. 2d 762 (S.D.N.Y. 2000)
  The vessel’s navigation was confined to “Inland & Coastal Waters of Hudson River between Verrazano Narrows Bridge & Albany, Including East River & Western Long Island Sound.” The court held the craft was not oceangoing, partly because its operations were linked to an inland river system and limited coastal stretches, not broad ocean sailing. The Fifth Circuit uses Mitlof as another example where restraints to inland/coastal rivers led to a finding of non-oceangoing status.

Taken together, these cases present a coherent picture, which the Fifth Circuit adopts:

• If the policy territory includes the ocean or its coastal waters in a meaningful way, the vessel is “ocean going.”
• If the policy confines the vessel to inland lakes, rivers, bays, or strictly inland/coastal river systems, without true ocean navigation, the vessel is not “ocean going.”

2. The Role of Jefferson Insurance Co. of N.Y. v. Cassella

Jefferson Ins. Co. of N.Y. v. Cassella, 261 F. Supp. 2d 160 (E.D.N.Y. 2003), noted in the opinion, explains how New York Insurance Law §§ 3420(i) and 2117(b)(3)(B) work together to exclude “insurance in connection with ocean going vessels” from certain statutory requirements, including restrictions on named-operator clauses.

Cassella therefore provides the statutory backdrop for Parr: once a vessel is characterized as “ocean going,” the consumer‑protective rule that generally invalidates named‑operator limitations does not apply. The Fifth Circuit adopts that interpretive framework and simply addresses whether the AFTER PARR T falls within the “ocean going” category.

3. Rejection of Royal Insurance Co. of America v. A & C Ship Fueling Corp.

Parr relied on Royal Ins. Co. of Am. v. A & C Ship Fueling Corp., No. CV 91‑3090, 1992 WL 219783 (E.D.N.Y. Mar. 21, 1992), which had suggested that a tugboat was not “oceangoing” even though the policy did not appear to limit it to particular waterways.

The Fifth Circuit distinguished and discounted Royal Ins. on multiple grounds:

• The tugboat in Royal Ins. apparently never actually entered the ocean, implying a factual difference.
• The policy in Royal Ins. did not expressly permit broad offshore ocean travel up to 250 miles from shore, unlike the policy at issue in Parr.
• Critically, the Royal Ins. decision was later vacated (see 1995 A.M.C. 504 (E.D.N.Y. July 21, 1994)), weakening its persuasive force.

By declining to treat Royal Ins. as authoritative, the Fifth Circuit reinforces the dominance of the more recent SDNY/EDNY line (Zaglool, DeGeorge, N.Y. Marine, Progressive, Mitlof) in defining “oceangoing” for insurance purposes.

4. General Maritime Law and Japan Line, Ltd. v. Los Angeles County

In a footnote, Parr contended that general maritime law defines “oceangoing vessel” as one engaged in interstate or foreign commerce on the high seas, citing Japan Line, Ltd. v. Los Angeles County, 441 U.S. 434 (1979), a case dealing with the constitutional treatment of international shipping containers and the Foreign Commerce Clause.

The Fifth Circuit rejected this argument, emphasizing:

• Japan Line addressed state taxation of instrumentalities of foreign commerce, not marine insurance; its terminology is context‑specific.
• Even if Japan Line uses a definition of “oceangoing vessel” for tax purposes, that does not create an “entrenched federal maritime law” rule applicable to insurance contract interpretation.
• The presence of a robust body of New York insurance law on this very question, and the parties’ contractual selection of New York law, forecloses resort to a broad, transplanted maritime definition from a tax case.

This reinforces a key doctrinal point: federal courts do not lightly displace party‑chosen state law by creating or importing general maritime rules, especially where the state’s law is detailed and well‑developed on the precise issue.

5. Appellate Preservation: Vargas v. McHugh

In footnote 2, the court notes two additional arguments raised by Yachtinsure:

1. That New York’s prohibition on named-operator clauses applies only to policies issued in New York upon vessels “garaged or used” in New York; and
2. That § 3420(e) applies only to third‑party liability coverage (i.e., coverage for injuries or damage the insured causes to others), not necessarily to first‑party hull coverage (damage to the insured’s own vessel).

The court declines to consider these arguments because they were not raised below, citing Vargas v. McHugh, 630 F. App’x 213, 217 n.3 (5th Cir. 2015). This adherence to ordinary preservation rules underscores that appellate courts typically confine themselves to issues properly presented to the district court.

B. The Court’s Legal Reasoning

1. Standard of Review and the 12(b)(6) Posture

The court reiterates two basic points of appellate review:

• Rule 12(b)(6) motions (failure to state a claim) are reviewed de novo, with all factual allegations accepted as true in the plaintiff’s favor, but with purely legal questions reviewed independently. If, even taking the facts as alleged, the policy unambiguously precludes coverage, a claim can be dismissed at this stage.
• Interpretation of an insurance policy is a question of law, also reviewed de novo. This is standard both in general contract disputes and in maritime insurance law.

Because the outcome turns entirely on the application of law (New York statutes and precedent) to the undisputed policy terms, the case is suited to resolution by motion to dismiss; no factual development is required.

2. The Choice-of-Law Clause and the Role of State Law

The policy chooses New York law subject to “entrenched” federal maritime law. This reflects contemporary marine insurance practice, shaped by:

• Wilburn Boat Co. v. Fireman’s Fund Ins. Co., 348 U.S. 310 (1955), holding that, in the absence of an established federal maritime rule, state law governs marine insurance disputes.
• Fifth Circuit precedent similarly recognizing that, unless a specific, uniform maritime rule exists, state law (often designated in the policy) fills the gap.

Parr argued for a general maritime definition of “oceangoing vessel” that would displace New York’s statutory and case law. The Fifth Circuit rejected this, effectively holding:

• There is no “well-established, entrenched” federal maritime definition of “oceangoing” that governs marine insurance policies.
• New York has a “well-developed jurisprudence” on precisely this question; respecting the parties’ contractual choice, New York law provides the rule of decision.

Thus, the court does not create or import federal common law of “oceangoing vessels”; it applies state law as the parties agreed.

3. The Policy’s Geographical Limits: Why the Vessel Is “Ocean Going”

The heart of the opinion is the court’s application of New York’s “policy territory” test to the specific navigational clause:

Policy territory:
“Eastport Maine to Brownsville Texas and the Bahamas (excluding Cuba) not exceeding 250 miles offshore.”

The court emphasizes that this territory:

• Runs along the entirety of the U.S. Atlantic and Gulf coasts; and
• Permits travel up to 250 miles offshore; and
• Includes the Bahamas, a region of open ocean navigation.

The court bluntly states: “We cannot fathom how that is not permission to go upon the ‘ocean.’” In other words, any reasonable reading of the policy recognizes that the vessel may operate on the open ocean, not just in sheltered inland waters.

Comparing to New York precedents:

• Zaglool and DeGeorge both found “oceangoing” status where policy limits allowed “Atlantic coastwise” navigation—arguably narrower than the 250‑mile offshore permission here.
• N.Y. Marine recognized “coastal waters” (necessarily part of the ocean) as sufficient to trigger oceangoing status.
• Progressive and Mitlof held vessels non-oceangoing where policies were confined to inland lakes, rivers, and bays, or narrow inland-and-coastal river systems; those limits are materially different from the expansive offshore range here.

Against that background, the Fifth Circuit concludes that, under New York law, there is no plausible argument that the AFTER PARR T is anything other than an “ocean going” vessel for purposes of the insurance statutes.

4. Rejection of Vessel-Type and Usage Arguments

Parr argued that:

• The vessel was a “pleasure craft,” and
• It was “prohibited from oceangoing travel” and “instead limited to operating near the coast.”

The court effectively rejects both lines of argument:

• New York’s “oceangoing” inquiry is not driven by whether a vessel is a commercial ship or a pleasure yacht, but by the policy’s navigational permissions.
• The policy’s 250‑mile offshore allowance plainly contemplates high‑seas or at least open‑ocean navigation; “near the coast” does not negate the fact that the waters involved are oceanic.

Thus, the statutory term “ocean going” is interpreted functionally and geographically, not by vessel category or the insured’s subjective expectations.

5. Consequence: The Named-Operator Clause Is Enforceable

Having classified the vessel as “ocean going,” the court’s legal conclusion follows tightly:

1. New York Insurance Law § 3420(e) (the generic ban on named‑operator clauses) does not apply to “insurance in connection with ocean going vessels” under §§ 3420(i) and 2117(b)(3)(B).
2. The policy in Parr falls into this oceangoing exception.
3. Therefore, the named-operator clause remains fully enforceable under New York law.
4. Because Parr concedes he was not a “named operator” within the meaning of the policy, he does not meet a condition of coverage.
5. His claim for hull damage, as pleaded, fails as a matter of law and is properly dismissed at the Rule 12(b)(6) stage.

The court does not need to reach policy issuance location, garaging/usage in New York, or the liability-vs-hull distinction in § 3420(e), given its decisive oceangoing holding.

C. Impact and Future Implications

1. Clarifying the “Policy Territory” Test for Oceangoing Status

The most immediate impact of Parr is an explicit endorsement by a federal appellate court (even in an unpublished opinion) of New York district-court jurisprudence defining “ocean going” vessels by:

• Examining the geographic scope of navigation permitted by the policy, and
• Differentiating ocean/coastal navigation from inland waterways.

In practice, this means:

• Any policy that allows operation on the open ocean or coastal waters (especially with substantial offshore range) will likely be deemed “in connection with ocean going vessels” for New York insurance law purposes.
• Owners of yachts, pleasure craft, or smaller vessels should not assume that being “recreational” or “non‑commercial” removes them from the “oceangoing” category if their policy permits open‑ocean navigation.

2. Effect on Drafting of Marine Insurance Policies

Insurers and brokers using New York law—or whose policies incorporate New York insurance law via a choice-of-law clause—may draw several lessons:

• Deliberate use of navigational limits. If insurers wish to rely on the oceangoing exception (to preserve named-operator clauses or other exclusions from § 3420), they can structure policy territory to include “ocean,” “coastal waters,” or explicit offshore ranges, following the patterns approved in Zaglool, DeGeorge, and now Parr.
• Clarity in terminology. Terms like “coastal waters” have been construed as inherently oceanic; insurers and insureds should understand that including such language is likely to trigger the “ocean going” classification.
• Risk for insureds who expect consumer-protective rules. Policyholders relying on New York’s prohibition of named-operator clauses need to realize that those protections vanish for oceangoing vessels; negotiating more favorable policy language up front becomes critical.

3. Influence on Other Courts and Circuits

Although Parr is unpublished and therefore non‑precedential within the Fifth Circuit, it may carry persuasive weight:

• Other federal courts—especially within the Fifth Circuit—may cite it as persuasive authority when construing policies that incorporate New York law in marine insurance disputes.
• Marine insurers commonly select New York law; a Fifth Circuit endorsement of the existing SDNY/EDNY interpretation of “oceangoing” will strengthen that body of law beyond the Second Circuit’s geographic boundaries.
• State and federal courts applying New York law may note that another circuit has accepted the New York district courts’ approach, reinforcing that it is a reasonable prediction of how New York’s highest court would rule.

4. Unresolved Questions Left for Another Day

The opinion explicitly does not resolve several important interpretive questions about New York Insurance Law § 3420, because they were not preserved below:

• Territorial reach of § 3420(e): Does its prohibition on named-operator clauses apply only to policies “issued” in New York on risks “garaged or used” in New York? The insurer hinted at such a limitation, but it remains undecided in this opinion.
• Coverage type: Does § 3420(e) govern only third‑party liability coverage (i.e., injuries/damage to others) and not first‑party hull coverage (damage to the insured vessel)? This is a significant doctrinal question that Parr expressly sidesteps.

Future litigants may test these questions in cases where the oceangoing status is ambiguous or where the vessel is plainly not oceangoing, yet insurers seek to avoid § 3420(e) on other grounds.

5. Reinforcing Contractual Choice of Law in Maritime Insurance

Parr also reinforces an important structural principle of maritime and insurance law:

• Where parties clearly choose a state’s substantive law to govern their marine insurance contract, and where that state has a developed body of law on the issue, federal courts will generally respect that choice.
• General maritime law will not be invoked to override that choice unless there is a genuinely “entrenched” federal maritime rule on point (e.g., a Supreme Court decision or a uniform rule widely accepted in maritime jurisprudence).

This is consistent with the broader trajectory of marine insurance law since Wilburn Boat, under which state law has substantial space to operate, particularly as to policy‑interpretive questions, unless uniformity is essential.

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V. Simplifying Key Legal Concepts

A. “Named-Operator Clause”

A named-operator clause is a policy provision that conditions coverage on operation of the insured vehicle or vessel only by specific named individuals. For example:

Coverage applies to the vessel only when operated by the following named operators: [list of persons].

If an accident occurs while someone else is operating the vessel—even the owner—coverage is excluded.

New York generally disfavors such clauses in certain personal lines of insurance (e.g., automobile liability policies) because they can undermine the public’s interest in ensuring that injured third parties have access to compensation. But for “insurance in connection with ocean going vessels,” New York law explicitly carves out an exception: insurers are permitted to use such clauses.

B. “Ocean Going” Under New York Insurance Law

In this context, “ocean going” does not mean “a giant cargo ship crossing oceans.” Instead, under New York case law, a vessel is “ocean going” if:

• The insurance policy allows the vessel to travel on ocean waters (including coastal ocean waters), not merely on inland rivers, lakes, or bays; and
• The navigational limits are not confined to purely inland or riverine systems.

A yacht that may travel in coastal ocean waters, or 250 miles offshore along the Atlantic or Gulf coasts, is “ocean going,” even if:

• It is used primarily for recreation.
• It rarely, or never, actually ventures far offshore.

The classification depends on what the policy permits, not on how the owner in fact uses the vessel.

C. Rule 12(b)(6) Motion to Dismiss

A motion under Federal Rule of Civil Procedure 12(b)(6) asks the court to dismiss a complaint because it “fails to state a claim upon which relief can be granted.” At this stage:

• The court assumes the complaint’s factual allegations are true.
• But it considers whether, even if those facts are true, the law entitles the plaintiff to relief.

In insurance disputes, if the policy language is clear and, as a matter of law, excludes coverage for the type of loss alleged (here because the operator was not named), a court can resolve the case on a 12(b)(6) motion without discovery or trial.

D. “Entrenched” Federal Maritime Law vs. State Law

“Entrenched federal maritime law” means a well-established, widely accepted rule of federal maritime common law—typically derived from:

• Supreme Court decisions, or
• Consistent, longstanding decisions from the federal courts of appeals.

If such a rule exists, it takes precedence over conflicting state law in maritime cases. If it does not exist on a particular subject (as with the definition of “oceangoing” for marine insurance purposes), courts generally look to:

• The parties’ contractual choice of law, and
• The relevant state’s substantive law.

In Parr, the court found no entrenched federal maritime rule defining “oceangoing” for this context, so New York law—chosen by the parties—controlled.

E. Appellate Preservation of Issues

Appellate courts generally do not consider arguments raised for the first time on appeal. Parties are expected to:

• Present their legal theories to the trial court first;
• Develop a factual and legal record there; and
• Only then seek appellate review of rulings on those theories.

In Parr, Yachtinsure presented two additional statutory arguments on appeal regarding the scope of New York Insurance Law § 3420(e). Because those arguments had not been raised below, the Fifth Circuit declined to address them, adhering to its normal practice as reflected in Vargas v. McHugh.

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VI. Conclusion: Significance of Parr v. Yachtinsure in the Broader Legal Landscape

Parr v. Yachtinsure might appear at first glance to be a routine coverage dispute about a pleasure yacht. Yet the Fifth Circuit’s analysis crystallizes several important principles at the intersection of maritime, insurance, and state regulatory law:

1. Policy navigational limits define “ocean going” status under New York insurance law.
   The opinion endorses New York precedent holding that a vessel is “ocean going” when its policy territory authorizes meaningful ocean or coastal navigation, regardless of whether the vessel is commercial or recreational and regardless of its actual usage.
2. Oceangoing vessels are exempt from New York’s ban on named-operator clauses.
   Because the AFTER PARR T was classified as “ocean going,” New York Insurance Law § 3420(e)’s prohibition of named-operator-only restrictions did not apply. This reaffirms that marine insurers may use such clauses in oceangoing contexts, shifting the burden to insureds to read and negotiate policy terms carefully.
3. Federal courts will honor state-law choices in marine insurance contracts, absent entrenched maritime rules.
   The case underscores the enduring influence of Wilburn Boat: parties’ choice of New York law is respected, and general maritime law is not expanded to supplant that choice without a well-established federal rule on point.
4. Unpublished but influential.
   Though not designated for publication and therefore non‑precedential in the Fifth Circuit, the decision is likely to be persuasive where similar choice-of-law and navigational-limit issues arise in marine insurance litigation, especially for vessels operating along the U.S. Atlantic and Gulf coasts.
5. Practical implications for policyholders and insurers.
   Yacht owners and other vessel operators cannot safely assume that New York’s consumer‑protective insurance rules apply to them if their policy permits ocean or coastal navigation. Insurers, conversely, may see Parr as confirming that carefully drafted navigational limits can bring policies within the oceangoing exception and preserve more restrictive operator provisions.

In sum, Parr v. Yachtinsure illustrates how a seemingly technical question—whether a policy’s navigational limits render a vessel “ocean going”—can decisively determine the enforceability of key policy restrictions and the availability of significant insurance coverage. It reinforces the primacy of contractual terms and chosen state law in marine insurance, and it provides a clear, geographically oriented framework for assessing “oceangoing” status under New York’s insurance statutes.

Note: This commentary is for informational and analytical purposes only and does not constitute legal advice.