{"id":78,"date":"2013-05-20T21:12:00","date_gmt":"2013-05-20T21:12:00","guid":{"rendered":"http:\/\/localhost:8080\/boatwp\/?p=78"},"modified":"2020-03-24T21:18:51","modified_gmt":"2020-03-24T21:18:51","slug":"the-changing-waterfront-after-lozmanthe-plaintiffs-lawyer-perspective","status":"publish","type":"post","link":"http:\/\/boatlawyer.com\/boatwp\/the-changing-waterfront-after-lozmanthe-plaintiffs-lawyer-perspective\/","title":{"rendered":"The Changing Waterfront \u2013 After Lozman: The Plaintiff\u2019s Lawyer Perspective"},"content":{"rendered":"\n

I. Introduction<\/strong><\/p>\n\n\n\n

Poet James Whitcomb Riley (1849\u20131916) may have coined the phrase when he wrote: \u201cWhen I see a bird that walks like a duck and swims like a duck and quacks like a duck, I call that bird a duck.\u201d  Now, the Supreme Court has echoed that parable by the development of the \u201creasonable observer\u2019s test, applying a \u201cpractical,\u201d not a \u201ctheoretical\u201d definition of  a \u201cvessel\u201d \u2013 holding that Fane Lozman\u2019s floating home was not a \u00a73 vessel [2]<\/a>\u2013 \u201c[b]ut for the fact that it floats, nothing about Lozman\u2019s home suggests that it was designed to any practical degree to transport persons or things over water.\u201d[3]<\/a><\/p>\n\n\n\n

This article is intended to provide guidance to the Plaintiff when determining whether a structure is a \u201cvessel\u201d sufficient to support admiralty jurisdiction.   \u201cIn Lozman<\/em>, the Supreme Court has sent a shot across the bow of those lower courts that have \u201cendorse[d] the \u2018anything that floats\u2019 approach\u201d to defining vessels.\u201d[4]<\/a>  The Lozman<\/em> criteria \u201coffer(s) guidance in a significant number of cases where the \u201ccapacity\u201d to transport over water is in doubt<\/em>.\u201d[5]<\/a><\/p>\n\n\n\n

The touchstone of admiralty jurisdiction rests upon the finding that the structure involved is a \u201cvessel,\u201d including maritime lien suits, marine insurance disputes, seaman\u2019s claims, and many others.  The Lozman<\/em> majority believes that \u201cin those borderline cases, the method used for resolution is workable; and unlike an \u201canything that floats\u201d test, it is consistent with statutory text, purpose, and precedent.\u201d[6]<\/a><\/p>\n\n\n\n

Lozman<\/em><\/strong> Criteria<\/strong><\/p>\n\n\n\n

As the majority observed, \u201cLozman\u2019s floating home was a house-like plywood structure with empty bilge space underneath the main floor to keep it afloat.\u201d  He had it towed several times before deciding on a marina owned by the city of Riviera Beach, Florida (\u201cCity\u201d).  After various disputes with Lozman and unsuccessful efforts to evict him from the marina, the City brought a federal admiralty lawsuit in rem <\/em>against the floating home, seeking a lien for dockage fees and damages for trespass. Lozman moved to dismiss the suit for lack of admiralty jurisdiction.  The District Court found the floating home to be a \u201cvessel\u201d under the Rules of Construction Act, which defines a \u201cvessel\u201d as including \u201cevery description of watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water,\u201d 1 U. S. C. \u00a73, concluded that admiralty jurisdiction was proper, and awarded the City dockage fees and nominal damages. The Eleventh Circuit affirmed, agreeing that the home was a \u201cvessel\u201d since it was \u201ccapable\u201d of movement over water despite the petitioner\u2019s subjective intent to remain moored indefinitely.\u201d[7]<\/a><\/p>\n\n\n\n

Reversing the Eleventh Circuit, the Lozman<\/em> majority reasoned that the Eleventh Circuit\u2019s interpretation was too broad.   \u201cNot every floating structure is a \u2018vessel.\u2019  To state the obvious,  a wooden washtub, a plastic dishpan, a swimming platform on pontoons, a large fishing net, a door taken off its hinges, or Pinocchio (when inside the whale) are not \u2018vessels,\u2019 even if they are \u2018artificial contrivance[s]\u2019 capable of floating, moving undertow, and incidentally carrying even a fair-sized item or two when they do so.  Rather, the statute applies to an \u2018artificial contrivance . . . capable of being used . . . as a means of transportation on water.\u2019\u201d[8]<\/a><\/p>\n\n\n\n

The Reasonable Observer Test<\/strong><\/p>\n\n\n\n

The Supreme Court\u2019s decision will be particularly remembered for articulating a new test to determine if a structure is a \u201cvessel\u201d.  The majority reasoned:<\/p>\n\n\n\n

\u201c[b]ut for the fact that it floats, nothing about Lozman\u2019s home suggests that it was designed to any practical degree to transport persons or things over water.  It had no rudder or other steering mechanism.  Its hull was unraked, . . . it had a rectangular bottom 10 inches below the water . . . no special capacity to generate or store electricity . . .  could obtain that utility only through ongoing connections with the land. Its small rooms looked like ordinary non-maritime living quarters.  And those inside those rooms looked out upon the world, not through watertight portholes, but through French doors or ordinary windows.  Although a lack of self-propulsion is not dispositive, it may be a relevant physical characteristic. And Lozman\u2019s home differs significantly from an ordinary houseboat in that it has no ability to propel itself.  . . . Lozman\u2019s home was able to travel over water only by being towed.  Prior to its arrest, that home\u2019s travel by tow over water took place on only four occasions over a period of seven years. And when the home was towed a significant distance in 2006, the towing company had a second boat follow behind to prevent the home from swinging dangerously from side to side.\u201d[9]<\/a> (Citations omitted)<\/p>\n\n\n\n

In light of these non-marine characteristics, the Lozman<\/em> majority ultimately held \u201c[t]he home has no other feature that might suggest a design to transport over water anything other than its own furnishings and related personal effects.  In a word, we can find nothing about the home that could lead a reasonable observer<\/em> to consider it designed to a practical degree for \u2018transportation on water.\u2019\u201d Id.<\/em><\/p>\n\n\n\n

Practical considerations for the \u201cReasonable Observer\u201d \u2013 Criteria for determining whether a structure is a \u201cvessel\u201d<\/strong><\/p>\n\n\n\n

In the fine common law tradition, recognizing several key decisions, the Lozman<\/em> majority opinion identified certain criteria that the reasonable observer should review in determining whether the structure at issue is a \u201cvessel.\u201d<\/p>\n\n\n\n

  1. \u201cUse of structure\u201d <\/strong>\u2013 wharf boat not a vessel \u2013 <\/strong>At oral argument, counsel for Lozman<\/em> was adamant that his client\u2019s structure was most similar to that in one particular case, Evansville & Browning Green Packet Co. vs. Chero Cola Bottling Co., <\/em>217 U.S. 19 (1926); the Court agreed,  It opined that \u201c\u2018a wharf boat was not<\/em> a vessel;\u2019 . . . it was floated next to a dock; it was used to transfer cargo from ship to dock and ship to ship; it was connected to the dock with cables, utility lines, and a ramp.  Id.<\/em> at 21.  Despite the fact that annually it was towed each winter to a harbor, \u201cit was not used to carry freight from one place to another, nor did it encounter perils of navigation to which craft used for transportation are exposed.\u201d  Id.<\/em> at 22.<\/li>
  2. \u201cWaterborne function\u201d \u2013 dredge was a vessel \u2013 <\/strong>the majority found support in Stewart v. Dutra Constr. Co.,<\/em> 543 U. S. 481, 496, which observed that dredges ordinarily<\/em> \u201cserved a waterborne transportation function, namely that \u2018in performing their work they carried machinery, equipment, and crew over water.\u2019  Id.<\/em> at 491-492.<\/li>
  3. \u201cEngaged in transportation\u201d \u2013 <\/strong>citing two lower court decisions for support, the Lozman<\/em> majority opinion raised examples, as follows:<\/li><\/ol>\n\n\n\n

    i    Bernard v. Binnings Constr. Co.<\/em>, 741 F.2d 824, 828, n. 13, 832, n. 25 (5th<\/sup> Cir. 1984), observed that a work punt was not a vessel<\/strong> \u2013 as the mere capacity to float or move across navigable waters does not necessarily make a structure a vessel<\/p>\n\n\n\n

    ii   Ruddiman v. A Scow Platform,<\/em> 38 F. 158 (S.D.N.Y, 1889) determined a scow was not a vessel<\/strong>, though \u201ccapable of being towed . . . though not without some difficulty, from its clumsy structure\u201d just a floating box, is not a \u201cvessel,\u201d because \u201cit was not designed or used for the purpose of navigation,\u201d not engaged \u201cin the transportation of persons or cargo,\u201d and had \u201cno motive power, no rudder, no sails\u201d)<\/p>\n\n\n\n

    \u201cOriginal design vs. later physical alterations\u201d <\/strong>original design is not always determinative \u2013 as Lozman<\/em> observed that a design based or purpose-related criterion is not always the test of the vessel, as \u201c[a] craft whose physical appearance and activities objectively evidence waterborne transportation purpose or function may still be rendered a non-vessel by later physical alterations \u2013 such as the [famous Cunard cruise ship] Queen Mary \u2013 where the owner takes a structure that is otherwise a vessel and connects it permanently to the land.\u201d<\/p>\n\n\n\n

    \u201cNewly designed structure\u201d \u2013 <\/strong>floating processing plant no longer vessel where a large opening had been cut into her hull, citing Kathriner v. Unisea, Inc.<\/em>, 975 F. 2d 657, 660 (CA9 1992).<\/p>\n\n\n\n

    The Lozman<\/em> Dissent<\/strong><\/p>\n\n\n\n

    Justice Sonia Sotomayor prepared a robust dissent and focused on the ramifications of the lack of an objective vessel determinative test.  \u201c[W]ithout knowing whether a particular ship is a \u00a73 vessel, it is impossible for lenders to know how properly to characterize it as collateral for a financing agreement because they do not know what remedies they will have recourse to in the event of a default.  . . . Similarly, cities like Riviera Beach provide docking for crafts like Lozman\u2019s on the assumption that such crafts actually are \u201cvessels,\u201d  . . .  The majority makes it impossible for these marinas to know whether the \u201chouseboats\u201d that fill their slips are actually vessels and what remedies they can exercise in the event of a dispute.  Moreover, the majority\u2019s decision reaches well beyond relatively insignificant boats like Lozman\u2019s craft, \u2026.. because it specifically disapproves of lower court decisions dealing with much larger ships, (questioning Holmes v. Atlantic Sounding Co.,<\/em> 437 F. 3d 441 (5th<\/sup> Cir. 2006) (finding a 140-foot-long and 40-foot-wide dormitory barge with 50 beds to be a 1 U.S.C. \u00a73 vessel)).\u201d[10]<\/a><\/p>\n\n\n\n

    Post Lozman<\/em> Decisions<\/strong><\/p>\n\n\n\n

    The dust did not have time to settle before courts around the country began to address the impact of the Supreme Court\u2019s ruling.  On January 22, 2013, in Lemelle v. St. Charles Gaming Co., Inc.,<\/em> the Supreme Court vacated the Louisiana State Appellate Court, Third Circuit\u2019s determination that a casino boat was not a vessel, granting certiorari, vacating the judgment, and remanding in light of Lozman.[11]   The state appellate court had previously reversed the trial court\u2019s determination that the Crown was a vessel and observed \u201cthat the Crown has been affixed in its dockside location, to some degree, since 2001 by lines and cables. It has not sailed since the 2001 legislation prohibiting it from conducting cruises or excursions.  In fact, since 2001, its crew size has been reduced due to the lack of need to tie and untie the Crown onto the dock.  According to the testimony of the Crown\u2019s captain, the Coast Guard no longer inspects the Crown.  Rather, at the time of the captain\u2019s deposition, inspections were performed by a state entity.  Mr. Lemelle asserts that the Crown\u2018s practice of operating its engine and thrusters should be viewed as indicative of its actual capacity for transportation or movement. Similarly, its navigation equipment is intact.  However, the practice referenced by Mr. Lemelle is not, in fact, used for navigation or transportation purposes.\u201d[12]<\/a><\/p>\n\n\n\n

    The Lozman <\/em>decision was also applied in a marine insurance case on January 25, 2013.  In Fireman\u2019s Fund Ins. Co., v. Great American Ins. Co.[12]<\/strong><\/a>,<\/em> involving a drydock, the district court judge observed that \u201cwhile arguably sufficient in a pre-Lozman landscape to prove the drydock a vessel, falls short post-Lozman.  Simply put, this Court cannot say that a reasonable observer would consider a drydock designed or \u2018regularly\u2019 used, to transport or things over water.\u201d  Finding that the drydock and the Lozman vessel are materially indistinguishable. <\/em>The Court went through an exhaustive reasonable observer<\/em> analysis, as follows:<\/p>\n\n\n\n

    While towable, the Drydock lacked the ability to propel itself.   Accord Lozman <\/em>2013 WL 149633, at *5 (citing the fact that \u201cLozman\u2019s home was able to travel over water only by being towed\u201d as evidence that the houseboat was not \u201cdesigned to any practical degree transport persons or things over water\u201d).  Nor did the Drydock have a steering mechanism.  Accord id.<\/em> (citing as additional evidence that \u2018[Lozman\u2019s home] had no rudder or other steering mechanism\u2019).  Similarly, it lacked navigational lights, lifeboats, a wheelhouse or other equipment that would allow it to be used for the transportation of passengers.  Dkt. No.202, Ex. C; accord Lozman. 2013 WL 149633, at *9 (noting that whether a boat is \u201cdesigned to any practical degree\u201d for the transportation of cargo or people is relevant to the inquiry). In addition, the Drydock was never used to transport cargo or people, and the living quarters were no longer in use when the drydock was stationed at Port Arthur. Dkt. 202, Ex. B (\u201cCates Dep.\u201d) at 212-213.<\/p>\n\n\n\n

    Moreover, while the drydock has been moved long distances at least twice in the distant past, it was, in the years leading up to its destruction, more or less permanently moored in one place. Dkt. No. 164 (\u201cHaley Decl.) at \u00b6 10. Although the drydock was still moved away from its mooring at least every two to three years for dredging of the seafloor beneath the drydock, Lozman <\/em>makes plain that this amount of transportation is not sufficient. Lozman<\/em>, 2013 WL 149633, at *5.<\/p>\n\n\n\n

    Lozman\u2019s house was not a drydock in part because \u201c[p]rior to its arrest, that home\u2019s travel by tow over water took place on only four occasions over seven years.\u201d More to the point, the drydock\u2019s later movements were brief and of short distances, and the short trips were made solely to allow for dredging the slip, Cates Dep. at 114-115, which is self-evidently not the sort of \u201ctransportation\u201d contemplated by the Supreme Court in Lozman<\/em>.  Indeed, this type of movement is not \u201ctransportation\u201d at all. See supra<\/em>, note 5.<\/p>\n\n\n\n

    Upon the release of the Lozman decision, on January 26, 2013, the Supreme Court also denied a petition for writ of certiorari in Grixi Mendez v. Anadarko Petroleum Corporation, et al.  In this case, Mendez sued Anadarko in Texas state court, seeking benefits under the Jones Act, 45 U.S.C. \u00a7 51, et seq. Anadarko removed on the basis that Mendez was not a Jones Act seaman because the RED HAWK Spar was not a \u201cvessel\u201d for the purposes of that Act.  Mendez moved to remand, Anadarko responded and on October 29, 2010, the court held that the RED HAWK Spar was not a vessel for the purposes of the Jones Act and remand was not appropriate.  The RED HAWK Spar is a floating oil-production facility, which sits in over 5,000 feet of water in the Gulf of Mexico approximately 210 miles from Sabine Pass, Texas.  The Spar is located on the outer continental shelf.  The two states closest to the Spar are Texas and Louisiana. Since 2004, six anchors sunk into the ocean floor have held it in place.    The court found the RED HAWK Spar is a permanently moored work platform designed to process gas extracted from the seabed and is not practically capable of marine transportation.  As a result, Mendez is not a Jones Act seaman because he had no connection with a vessel in navigation.[13]<\/a><\/p>\n\n\n\n

    Lastly, in Mooney v. W&T Offshore, Inc.<\/em>, No. 2:12-cv-969 (E.D. La. Mar. 3, 2013), in light of Lozman<\/em>, District Judge Lance M. Africk held that the MATTERHORN SEASTAR, a tension leg platforms (\u201cTLP\u201d) \u2013 a floating oil and gas production structure that has been secured to the Outer Continental Shelf off the coast of Louisiana since 2003 by six mooring tendons \u2013 was not a vessel as a matter of law.<\/p>\n\n\n\n

    Conclusion<\/strong><\/p>\n\n\n\n

    Following Lozman<\/em>, Plaintiff\u2019s counsel must engage in a vessel-determinative analysis, as a reasonable observer, to determine whether the prospective in rem <\/em>defendant is a \u201cvessel\u201d and in cases where the basis for admiralty jurisdiction rests on the finding of a vessel, the Plaintiff\u2019s counsel must utilize the Lozman criteria to make such a determination.  In borderline cases, I would recommend that counsel employ the use of marine surveyors, engineers or other experts to assist in this determination, such as Anadarko commissioned in Red Hawk spar case.[14] The district courts have only begun to unpeel the layers that are the Lozman decision.  As they do, more previously settled structures will be reexamined to confirm their status \u2013leaving a plaintiff with some uncertainty in the coming years.  But overall, compared to the \u201canything but floats\u201d previous 11th<\/sup> Circuit test, the Supreme Court\u2019s new \u201creasonable observer\u201d test is a welcome tool for plaintiffs and their counsel around the country.<\/p>\n\n\n\n

    \n\n\n\n

    [1]<\/a> \nCaptain Robert L. Gardana is a licensed U.S.C.G. Master and Maritime \nAttorney for over 30 years.  He is the founder and president of Robert \nL. Gardana, P.A..  His practice focus is maritime law, maritime liens, \npassenger and crew claims, and personal injury.   His contact is Robert \nL. Gardana at Robert L. Gardana, P.A., 12350 SW 132nd<\/sup> Court, Suite 204, Miami, Fl  33186, website: www.BoatLawyer.com<\/a>  e-mail: Gardanalaw@gmail.com<\/a><\/p>\n\n\n\n

    [2]<\/a> Lozman v. City of Riviera Beach<\/em>, 2013 WL 149633, 133 S.Ct. 735, (Jan. 15, 2013)<\/p>\n\n\n\n

    [3]<\/a> 2013 WL 149633, at *7, Id. at 741-744.<\/p>\n\n\n\n

    [4]<\/a> Fireman\u2019s Fund Ins. Co., v. Great American Ins. Co., 2013 WL 311084 (S.D.N.Y. January 25, 2013).<\/p>\n\n\n\n

    [4]<\/a> 2013 WL 149633, at *8<\/em>.<\/p>\n\n\n\n

    [5]<\/a> Id.<\/em>  Nor do we believe that the dissent\u2019s approach would prove any more workable.   For example, the dissent suggests a relevant distinction between an owner\u2019s \u201cclothes and personal effects\u201d and \u201clarge appliances (like an oven or a refrigerator).\u201d Post, at 752 (opinion of SOTOMAYOR, J.). But a transportation function need not turn on the size of the items in question, and we believe the line between items being transported from place to place (e.g., cargo) and items that are mere appurtenances is the one more likely to be relevant.   Cf<\/em>. Benedict, American Admiralty s 222, at 121 (\u201cA ship is usually described as consisting of the ship, her tackle, apparel, and furniture \u2026\u201d).<\/p>\n\n\n\n

    [6]<\/a> Id.<\/em>2013 WL 149633, 737 Syllabus<\/p>\n\n\n\n

    [7]<\/a> Id.<\/em>at *4.<\/p>\n\n\n\n

    [8]<\/a> Id.<\/em>2013 WL 149633, 737 Syllabus<\/p>\n\n\n\n

    [9]<\/a> Id. <\/em>2013 WL 149633, Id<\/em>. at 744-746.<\/p>\n\n\n\n

    [10]<\/a> 2013 WL 215486 (U.S.La.).<\/p>\n\n\n\n

    [11]<\/a> Lemelle v. St. Charles Gaming Co., Inc., <\/em>86 So.3rd<\/sup> 627 (La. 2012).<\/p>\n\n\n\n

    [12]<\/a> 2013 WL 311084<\/em> (S.D.N.Y. January 25, 2013)<\/p>\n\n\n\n

    [13]<\/a> The RED HAWK Spar is a cell spar comprised of smaller \u201ctube\u201d cells that together serve as the 560-foot hull, allowing for greater stability. The RED HAWK is comprised of six twenty-foot diameter tubes surrounding the seventh tube. The tubes are \u201cbundled\u201d to form the equivalent of a hull that is sixty-four feet in diameter; it has no means of self-propulsion; its work platform consists of three individual decks, sits on top of the hull.  It supports a twelve-man living quarter, crane, boom, helideck, power generators, production equipment, mono-ethylene-glycol recovery unit, heaters, glycol storage tanks, utilities, pipeline launchers, and receivers, and safety and survival capsules. Its deck is 55 feet by    74 feet and the main and production decks are 105 feet by 135 feet.  In 2004, the Spar was floated into place on its side, righted, and attached to the anchors by the six permanent mooring lines. When the Spar was installed, the suction anchors were first put in place, then the hull was towed and upended by flooding the lower segments. The hull was then moored. The deck was lifted onto the hull and fixed in place. The lines were then installed.  In addition to these mooring lines, an underwater infrastructure of flow lines and export pipeline systems, as well as umbilicals extending from the Spar to the subsea wellheads, used to transport oil and gas to shore-based facilities attach the Spar to the ocean floor. A pipeline extends from the Spar to the Pelican Gas Plant in Patterson Louisiana, by way of the VR-397 platform. The gas comes from the wellheads on the seafloor, up through the flow lines (steel pipes), then to the platform. Once on the platform, a separator takes the liquids out, and the gas flows to shore through a sixteen-inch steel pipeline.<\/p>\n\n\n\n

    [14] Anadarko has no plans to move the RED HAWK Spar.  Anadarko commissioned a study on the feasibility of having the Spar moved to another field approximately 100 miles away. The study concluded that doing so would take approximately 50 days and cost over $42 million. The actual movement of the Spar would take only 2 to 4 of those 50 days; the greatest time and difficulty were presented by preparing to move it and modifying it to anchor it in the new location. Only the Spar itself would be moved; the mooring system, and the risers and umbilicals, would all have to be severed or disconnected. The mooring system would either be disposed of or left in place. Anadarko would have to build a new mooring system at the new location if it decided to have the Spar moved. There are no plans to do so.<\/p>\n","protected":false},"excerpt":{"rendered":"

    I. Introduction Poet James Whitcomb Riley (1849\u20131916) may have coined the phrase when he wrote: \u201cWhen I see a bird that walks like a duck and swims like a duck and quacks like a duck, I call that bird a duck.\u201d  Now, the Supreme Court has echoed that parable by the development of the \u201creasonable […]<\/p>\n","protected":false},"author":2,"featured_media":95,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[3,6],"tags":[],"class_list":["post-78","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-maritime-law","category-insurance-litigation"],"_links":{"self":[{"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/posts\/78","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/comments?post=78"}],"version-history":[{"count":4,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/posts\/78\/revisions"}],"predecessor-version":[{"id":100,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/posts\/78\/revisions\/100"}],"wp:featuredmedia":[{"embeddable":true,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/media\/95"}],"wp:attachment":[{"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/media?parent=78"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/categories?post=78"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/boatlawyer.com\/boatwp\/wp-json\/wp\/v2\/tags?post=78"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}