Precedents Cited and Their Influence

1) Limitation of Liability Act framework

• Maryland Casualty v. Cushing, 347 U.S. 409 (1954): Recognizes the Limitation Act’s purpose to protect American shipowners by capping liability to vessel value and pending freight. The court cites Cushing to situate limitation actions within longstanding admiralty policy.
• Lewis v. Lewis & Clark Marine, Inc., 531 U.S. 438 (2001), and Providence & N.Y. S.S. Co. v. Hill Mfg. Co., 109 U.S. 578 (1883): Explain the historically skeletal drafting of the Limitation Act and the judiciary’s role—now expressed in Supplemental Rule F—in structuring limitation proceedings.
• Hartford Accident & Indemnity Co. v. Southern Pacific Co., 273 U.S. 207 (1927): The limitation court’s jurisdiction “attaches” by reason of its custody of the res—the limitation fund. This supports the court’s in rem/bankruptcy analogy.

2) Sovereign immunity’s sources, scope, and triggers

• Hans v. Louisiana, 134 U.S. 1 (1890); Alden v. Maine, 527 U.S. 706 (1999): Sovereign immunity springs from the Constitution’s structure, not solely the text of the Eleventh Amendment. The court uses these to explain why immunity is broad, structural, and dignity-protecting.
• P.R. Aqueduct & Sewer Auth. v. Metcalf & Eddy, Inc., 506 U.S. 139 (1993): Denial of sovereign immunity is immediately appealable (collateral order doctrine); the jurisdictional posture of Maryland’s interlocutory appeal is proper.
• Pennhurst State School & Hospital v. Halderman, 465 U.S. 89 (1984): Immunity limits Article III judicial power; clarifies Ex parte Young’s limits (no use to enforce state law).
• Franchise Tax Board of California v. Hyatt, 587 U.S. 230 (2019): Emphasizes immunity’s state-sovereignty/dignity component, applicable across forums.
• Lewis v. Clarke, 581 U.S. 155 (2017): Courts look past captions to the “real party in interest” when suit is nominally against an entity/official; used to explain when immunity is implicated without naming the State.
• Edelman v. Jordan, 415 U.S. 651 (1974): Retrospective monetary relief against state treasury implicates immunity; helps distinguish when relief is coercive against the State.
• Idaho v. Coeur d’Alene Tribe, 521 U.S. 261 (1997); Verizon Maryland, Inc. v. PSC of Maryland, 535 U.S. 635 (2002): Outline Ex parte Young and limits, reinforcing that only certain prospective, federal-law claims bypass immunity in official-capacity suits.
• Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996); Fitzpatrick v. Bitzer, 427 U.S. 445 (1976): Congress’s power to abrogate immunity is limited; § 5 of the Fourteenth Amendment is a recognized source.
• PennEast Pipeline Co. v. New Jersey, 594 U.S. 482 (2021); Torres v. Texas DPS, 597 U.S. 580 (2022): “Plan of the Convention” waivers—States consented at the Founding to some suits (e.g., by the federal government, other states, and certain Article I powers). The Fourth Circuit notes these to situate waiver/abrogation doctrine, then explains it is unnecessary here because immunity is never implicated.

3) In rem proceedings, bankruptcy analogy, and non-coercion

• Tennessee Student Assistance Corp. v. Hood, 541 U.S. 440 (2004): Discharge proceedings do not implicate state sovereign immunity because bankruptcy jurisdiction centers on the debtor’s estate (the res); even summons to a State for the discharge determination was not “coercive.” This is the cornerstone analogy for limitation actions.
• Central Virginia Community College v. Katz, 546 U.S. 356 (2006): Differentiates from Hood—some bankruptcy turnover actions might implicate immunity, but States consented (“plan of the Convention”). The Fourth Circuit uses Katz to show why the abrogation/waiver framework is irrelevant here: Jackson Creek’s limitation action is like Hood’s discharge, not a turnover claim against the State.
• California v. Deep Sea Research, Inc., 523 U.S. 491 (1998); The Davis, 77 U.S. 15 (1869); Pennoyer v. Neff, 95 U.S. 714 (1877): Prize and other in rem proceedings can bind state interests without offending immunity where the process does not invade the State’s possession. The Eleventh Circuit relied on this analogy in Bouchard; the Fourth adds that bankruptcy is even closer.
• Maryland v. Antonelli Creditors’ Liquidating Trust, 123 F.3d 777 (4th Cir. 1997): Financial pressure to file claims (or risk forfeiture) is not coercive judicial process haling the State into court in violation of immunity. The panel uses this to reject Maryland’s argument that the Limitation Act’s stay and single-forum structure “coerced” participation.

4) Sister Circuits on point

• Magnolia Marine Transport Co. v. Oklahoma, 366 F.3d 1153 (10th Cir. 2004): Sovereign immunity not implicated when a State files a claim in a limitation action; neither the State nor its officer is a defendant.
• Bouchard Transportation Co. v. Updegraff, 147 F.3d 1344 (11th Cir. 1998): Limitation proceeding sufficiently analogous to in rem prize, not a suit against the State.
• The Fourth Circuit expressly joins these courts, adding the bankruptcy framework as an even closer analog.

Legal Reasoning

1. Start with implication, not waiver/abrogation:

   The court meticulously separates three distinct questions: (a) whether sovereign immunity is implicated at all; (b) if so, whether it has been waived (by the State) or abrogated (by Congress under recognized powers, e.g., § 5 of the Fourteenth Amendment); and (c) the merits. It resolves the case at step (a)—immunity is not implicated—so steps (b) and (c) are unnecessary.

2. Two routes to implication; neither applies:
   • Coercive judicial process: Implication arises when a State is haled into court as a defendant and subjected to the court’s coercive power. Here, the Limitation Act lets a shipowner file a complaint in admiralty and create a limitation fund (the res), after which potential claimants are notified. Maryland was not named as a defendant or served to compel appearance; it chose to file a claim and to contest limitation. That is not “coercion.”
   • Real party in interest: This analysis applies where suits name officials or entities other than the State; it polices end-runs around immunity. Not relevant here because Maryland appeared in its own name.
3. Bankruptcy is the closest analog (Hood):

   The limitation action’s architecture resembles an in rem bankruptcy proceeding. The court’s jurisdiction rests on the res (the limitation fund). Claimants may file claims but are not sued as defendants; the proceeding ends with a distribution and discharge-like effect (liability capped and remaining claims cease). As in Hood, even where a State’s fiscal interests are affected, no coercive judicial process is directed at the State itself.

4. Financial pressure is not legal coercion:

   Maryland argued that the stay of other actions and the risk of default “compelled” it to appear. The Fourth Circuit, citing Antonelli, rejects that theory: financial incentive to participate—or risk forfeiture—does not transform a non-coercive, in rem-like proceeding into an affront to sovereignty. Notice to potential claimants is not the same as service of process, and the stay is directed at other fora and litigants, not at compelling the State’s appearance as a defendant.

5. Katz and plan-of-the-Convention are beside the point:

   Katz dealt with turnover/avoidance actions that might be coercive and therefore require an explanation rooted in the Bankruptcy Clause’s plan-of-the-Convention waiver. Here, the court analogizes limitation to a discharge (Hood), not turnover. Because immunity is not implicated at all, no waiver/abrogation analysis is necessary.

6. Issues not decided:

   The court does not reach Maryland’s Rules Enabling Act challenge to Supplemental Rule F(5). Under Swint and related authority, the interlocutory appeal is confined to sovereign immunity. Thus, challenges to Rule F’s validity—asserted to be substantive—remain for another day in the district court (or a different appeal).

Impact and Implications

• Binding rule in the Fourth Circuit: States that file claims in federal limitation proceedings cannot derail the action or avoid the liability cap by invoking sovereign immunity. District courts within the Fourth Circuit can proceed to adjudicate limitation without pausing for sovereign-immunity concerns where the State voluntarily appears.
• Strategic landscape for States: Transportation departments and other state agencies cannot use immunity as a shield to preserve full recovery once they choose to file claims in limitation. Declining to file may forfeit recovery (as a practical matter), but filing will not allow a subsequent immunity-based dismissal of the limitation action.
• Maritime certainty and uniformity: The decision promotes the Limitation Act’s goal of single-forum, fund-based resolution and aligns the Fourth Circuit with the Tenth and Eleventh Circuits—reducing interstate divergence and uncertainty in maritime incidents that implicate state property.
• Analogy canon strengthened: The opinion deepens the Supreme Court’s bankruptcy/in rem analogy for non-coercive, res-centered proceedings where States’ fiscal interests are affected but their dignity is not offended by being made defendants.
• Open questions preserved:
  • The validity of Supplemental Rule F(5) under the Rules Enabling Act is expressly not decided.
  • Edge scenarios—e.g., if a limitation court were to issue orders directly compelling a State or its officers to perform acts in personam (akin to turnover) or to invade state possession—are not before the court.
  • The merits of limitation (e.g., “privity or knowledge,” the valuation of the fund) remain to be litigated below.