Florida's "Cruises to Nowhere" Industry: Current Status and Future Prospects

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Florida's "Cruises to Nowhere" Industry: Current Status and Future Florida's "Cruises to Nowhere" Industry: Current Status and Future

Prospects Prospects

Robert Jarvis

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Robert Jarvis,

Florida's "Cruises to Nowhere" Industry: Current Status and Future Prospects

, 21

Gaming L.

Rev. & Econ.

18 (2017),

Available at: https://nsuworks.nova.edu/law_facarticles/374

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Florida’s ‘‘Cruises to Nowhere’’ Industry:

Current Status and Future Prospects

Robert M. Jarvis

I. INTRODUCTION

btaining reliable information about the

‘‘cruises to nowhere’’ (CTN)

industry in Flor-

ida

always has been difficult.

As an unlicensed

and unregulated form of gambling,

Florida’s

CTN industry, which has existed since 1984,

has

tended to attract operators who, for a variety of rea-

sons, have preferred to maintain a low profile.

The

most notable exception—SunCruz Casinos’ brash

Keywords: casino boats; cruises to nowhere; floating casinos;

gambling ships; offshore gambling; unregulated gambling

Robert M. Ja rvis is a professor of law at Nova Southeastern

University in Fort Lauderdale-Davie, Florida, and a m ember

of the Editorial Board of GamingLawReviewandEconomics.

The term ‘‘cruises to nowhere’’ (CTN) originated during Prohib-

ition (1920–33), when ships would sail out to international waters

so that passengers could imbibe alcohol. See, e.g., Law Sought to

Bar ‘‘Nowhere’’ Cruises: American Ship Companies Will Ask

Congress to Act Against Foreign Lines; Drinking on Trips

Cited—Custom Officials Get Protest that 18th Amendment and

Coastal Acts Are Violated, N.Y. Times, Oct. 24, 1931, at 37.

See also Daniel Okrent, Last Call: The Rise and Fall

of Prohibition 375 (2010) (‘‘‘[B]ooze cruises’ disappeared alto-

gether by 1938. On the other hand, the ‘cruise to nowhere’ begat

every passenger liner that [now] departs a U.S. port. . ’’ ).

Although this article is focused on Florida, CTN also currently

take place in Georgia (from Brunswick, 70 miles north of Jack-

sonville, aboard the Emerald Princess II—see <http://www

.emeraldprincesscasino.com/>) and in South Carolina (from

Little River, 25 miles north of Myrtle Beach, aboard the Big ‘‘M’’

I and Big ‘‘M’’ II—see <http://www.bigmcasino.com/>). Former

CTN jurisdictions include Massachusetts, New York, and Texas.

See Day Ships and Casino Cruises, Gaming Floor, <http://

www.gamingfloor.com/DayShips.html>.

Patently illegal CTN are not included in the present discus-

sion. See, e.g., United States v. Montford, 27 F.3d 137 (5th Cir.

1994) (defendants knew that Mississippi did not permit such

cruises). Likewise, CTN that do not offer gambling are excluded.

See, e.g., Duluth Superior Excursions, Inc. v. Makela, 623 F.2d

1251 (8th Cir. 1980). Because riverboats and multi-day cruises

represent distinct forms of shipboard gambling, see Robert M.

Jarvis et al., Gaming Law: Cases and Materials 397

(2003), they, too, are omitted.

See Lori Pennington-Gray, Florida’s Day Cruise Industry: A

Significant Contributor to Florida’s Economy?, in Cruise

Ship Tourism 290–98 (Ross Kingston Dowling ed., 2006) (ob-

serving, id. at 292, ‘‘It is fairly interesting that the value of the

DCI [day cruise industry] has not been documented. In addition,

it is odd that a profile of the industry is lacking from academic

textbooks and manuscripts.’’).

With few-to-no reporting requirements, how much Florida’s

CTN operators annually earn has long been a closely guarded

secret. In 1997, Da niel Pollock of the Fl orida Greyhound

Tracks Association ‘‘ballparked’’ the amount at $172 million,

which at the tim e worked out to $7 million per ship. See Tyler

Bridges, Casino Boats’ Revenue is Elusive Figure—One Esti-

mate Puts It at $172 Million, Miami Herald,Nov.23,1997,

at 17A. In 2000, Gus Boulis sold the equivalent of 10 CTN

vessels for $14.5 million each. See infra note 7. By then,

bot h government officials and the media routinely were

using the figure $500 million, for an average of $25 million

per boat. See, e.g., Jan Glidewell, Who’s Stacking the

Deck?, St. Petersburg Times,Feb.7,2000,at1(Citrus

Times) (‘‘Gambling ‘crui ses to nowhere’ have be en going on

for well over a decade. . In all, it is generally agreed to be

a $500-million-per-year industry. . ’’ ) .

CTN are subject to a federal statute known as the Gambling

Ship Act of 1948 (GSA), 18 U.S.C. §§ 1081–1083. The GSA

was enacted to combat a fleet of gambling ships stationed off

the coast of Los Angeles. See Ernest Marquez, Noir

Afloat: Tony Cornero and the Notorious Gambling

Ships of Southern California (2011). The law ‘‘prohibit[s]

American citizens (or residents) from owning or running gam-

bling ships and . prohibit[s] American-flagged ships from

being [used as] gambling ships.’’ O. Shane Balloun, The True

Obstacle to the Autonomy of Seasteads: American Law

Enforcement Jurisdiction Over Homesteads on the High Seas,

24 U.S.F. Mar. L.J. 409, 413 (2011–12) (footnotes omitted).

In 1994, Congress relaxed the GSA, thereby giving birth to

the modern CTN industry:

At one time, the Gambling Ship Act flatly prohibited gambling

aboard American-flag vessels engaging in interstate and for-

eign commerce, anywhere. See 18 U.S.C.A. §§ 1081–1082

(West 1984). The existence of the cruise-to-nowh ere industry

depends upon a 1994 amendment to the Act, which created

exceptions for vessels on certain cruises, defined by reference

to a provision of the Internal Re venue Code as of 1994

that levies a tax on the gambling revenues of such cruises.

GAMING LAW REVIEW AND ECONOMICS

Volume 21, Number 1, 2017

 Mary Ann Liebert, Inc.

DOI: 10.1089/glre.2017.2115

(footnote 4 continued) See Violent Crime Control and Law

Enforcement Act of 1994, Pub .L. No. 103-322, § 320501,

108 Stat. 1796, 2114–15 (1994) (amending 18 U.S.C.

§ 1081). In 1994, the Internal Re venue Code defined such

cruisesas(inter alia) those that return within 24 hours to

their port of embarkatio n and conduct gambling (subject to

federal taxation) ‘‘beyond the territorial waters of the United

States.’’ 26 U.S.C. § 4472 (1994).

United States v. One Big Six Wheel, 166 F.3d 498, 499 (2d Cir .

1999).

The modern CTN industry also relies on a set of 1992 changes to

the Johnson Act, 15 U.S.C. §§ 1171–1178, which was enacted in

1951 to thwart the interstate transportation of gambling devices:

The 1992 amendments altered the Johnson Act’ s general ban

on maritime gambling. Prior to the amendments, it was ‘‘un-

lawful to manufacture, recondition, repair , sell, transport, pos-

sess, or use any gambling device . within the special

maritime’’ jurisdiction of the United States. 15 U.S.C.A. §

1175 (1990). The Justice Department, however, inter-

preted this prohibition not ‘‘to apply to foreign-flag ves-

sels entering the United States.’’ H.R. Rep. No. 102-357

(1991). The effect was that Americ an flag vessels were

restricted from offering gambling to their passengers

while foreign flag vessels were free to do so. This put

American flag vessels at a competitive disadvantage i n

the lucrative leisure cruise industry. See id.

Congress reacted to the disparity by amending the

Johnson Act to make clear that it applied to vessels

‘‘documented unde r the laws of a foreign country.’’ 15

U.S.C. § 1175(a). Additionally, Congress crafted excep-

tions to the Johnson Act’s blanket restrictions related to

gambling devices. First, section 1175 no longer restricts

the transport and possession of gambling devices on ves-

sels, provided that those devices are not used while the

vessel is within the boundaries o f a state or possession

of the United States. Id. § 1175(b)(1)(A)–(B). Second,

section 1175 no longe r prohibits the repair and use of

gambling devices outside of those boundaries, unless

the ship is on a cruise to nowhere a nd the state in

which that c ruise ‘‘begins and ends has enacted a statute

the terms of which prohibit that repair or use on that voy-

age.’’ Id. § 1175(b)(1)(A), (b)(2).

Casino Ventures v. Stewart, 183 F.3d 307, 309 (4th Cir. 1999 ),

cert. denied, 528 U.S. 1077 (2000).

As has been explained elsewhere, the 1992 amendments

were included in an obscure bill known as the Flower Garden

Banks National Marine Sanctuary Act. See Customs Letter

Ruling 113479 ( June 29, 1995) (Arthur P. Schifflin, Chief—

Carrier Rulings Branch), available at <https://rul ings.cbp

.gov/detail.asp?ru=113479&ac=pr> (‘‘Under the Gambling

Devices Act of 1962 (Pub. L. 87-840, which enacted 15 U.S.C.

§ 1178, and amended 15 U.S.C. §§ 1171, 1172, and 1173) the

possession, transportation, and use of gambling devices w as

expressly prohibited on U.S.-flag vessels. On March 9, 1992,

the President signed into law Pub. L. 102-251, the Flower

Garden Banks National Marine Sanctuary Act, section 202 of

which amends section 2 of the Act of January 2, 1951 (15

U.S.C.§1172,commonlyreferredtoasthe‘JohnsonAct’),

section 5 of that Act (15 U.S.C. § 1175), and the first section of

that Act (15 U.S.C. § 1171).’’).

In 1996, Representative James E. King (R-Jacksonville)

proposed that Florida ‘‘opt out’’ of the 1992 amendments (as it

had the right to do, see Fla. Att’y Gen. Op. 95–70, available

at 1995 WL 698073), but the legislation died in committee

over concerns that doing so would cost the state jobs and

revenue. See Florida Senate, Cruises to Nowhere, Interim

Project Rep. 2004-138, Nov. 2003, at 2–3, available at

<http://arch ive . fls enate .gov/dat a/P u b licat ion s/2004/Senate/

reports/interim_reports/pdf/2004-138ft.pdf> [hereinafter Flor-

ida Senate 2003 Report] (discussing H.B. 2373 and S.B. 1906).

See Florida Senate 2003 Report, supra note 4, at 4 (‘‘Cruises to

nowhere have been operating out of Florida since 1984. The

industry has grown from 1 ship in 1984 to seventeen today’’).

Prior to 1984, Florida had hosted occasional ‘‘one-off’’ CTN.

In 1982, for example, the University of Miami baseball team

organized such a cruise as a fundraiser. See Christine Brennan,

Cruising to Nowhere, Miami Herald, Sept. 27, 1982, at 3D

(‘‘[Coach] Ron Fraser’s ship came in, complete with gourmet

dining, casino gambling, Las Vegas dancers, a comedy team and

entertainer Vic Damone. Saturday night’s Cruise to Nowhere,

the latest of Fraser’s promotional ideas, was a rousing success

for his Hurricane baseball program. ‘It went great,’ Fraser said.

‘We had a standing-room-only crowd of over 900 and turned 60

away.’’). See also Larry Birger, Coach Fraser’s Formula: Play

Hard, Sell Hard, Miami Herald, Aug. 30, 1982, at 10BM

(explaining that guests paid ‘‘$125 [per] ticket for a special four-

hour ‘Cruise to Nowhere’ Sept. 25 aboard the M/S Starward’’).

In 1984, Fantasy Cruises announced it was going to begin

regular CTN out of Fort Lauderdale using a Greek ship called

the Amerikanis. Built in 1952 by Harland and Wolff (the Belfast

firm responsible for the Titanic), the ship’s original owner had

been London’s Union-Castle Line, which ran freighters to

Africa. In 1967, after being sold to Chandris Lines (now

Celebrity Cruises), the vessel was given a new name, a new flag,

and a retrofit that made her suitable for Caribbean cruising. See

SS Amerikanis, Wikipedia: The Free Encyclopedia, <https://

en.wikipedia.org/wiki/SS_Amerikanis>.

Conscious of the fact that the GSA barred ships whose primary

purpose was gambling, see United States v. Black, 291 F. Supp.

262 (S.D.N.Y. 1968), executives stressed that the Amerikanis

would not focus on gambling:

‘‘This is the first time anybody in the country has had a

cruise like this,’’ said James Connolly, Port Everglades di-

rector. ‘‘People can sort of get a taste for cruising.’’ On

the Amerikanis, a full-sized steamship, South Florida resi-

dents can partake of the usual cruise activities—drinking,

dancing, dining and gambling.

‘‘We think there are a great amount of people who would

take a cruise to nowhere,’’ said Leo Robbins, executi v e vice

president for Fantasy Cruises. ‘‘The time comes when all

kinds of new ideas prove successful.’’

Robbins said the lure of the ocean, and not the itch for

gambling, will attract local residents to the cruise. He ex-

pects as many as 400,000 people will board the ship next

year at Port Everglades.

‘‘It’ s not a casino trip at all,’’ he said.

Added Connolly: ‘‘These are not gambling ships. There’s

no heavy action out there. ’’

David Satterfield, Firm Gambles on Cruises to Nowhere, Miami

Herald, July 21, 1984, at 1BR.

Hedging its bets, the Amerikanis offered a standard five-day

Caribbean cruise during the week and CTN on the weekends:

Fantasy Cruises says its S/S Amerikanis will begin sailing

year-round from Port Everglades beginning Oct. 12.

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 19

(footnote 5 continued) A ‘‘cruise to nowhere’’ will depart the

Fort Lauderdale gateway at 8 p.m. each Friday and Saturday,

returning to Port Everglades at 7 the following morni ng at a

cost of $49 per person, double occupancy. The price includes

dinner, buffet and nightclub show.

The vessel sails again on a ‘‘cruise to nowhere’’ at 10 a.m.

each Saturday and Sunday, returning to Port Ever glades at 6

p.m. The tab is $39 per person including lunch. Cabins, port

and service charges additional.

To complete the itinerary, the Amerikanis will depart Sun-

days at 8 p.m. for a fiv e-night cruise to Nassau [in the Baha-

mas] and Ocho Rios [in Jamaica].

Travel Tips, Palm Beach Post,Aug.5,1984,atG1.

As planned, the Amerikanis began service in October. By De-

cember, the experiment was over. After fewer than 20 voyages,

Fantasy announced that because of low ridership, the vessel was

being redeployed to Puerto Rico. See Julie Calsi, Sinking Num-

bers Forces Ship to Sail Away from Port, Miami Herald, Dec.

31, 1984, at 2BR.

Sensing an opportunity, Scandinavian World Cruises (soon to

become SeaEscape), one of Florida’s ‘‘one-day’’ operators—so

dubbed because their ships would sail to the Bahamas and back

in a single day—hurriedly mov ed to fill the void. See David

L yons, Scandinavian May Escape Total Disaster Yet, Miami

Herald, Aug. 12, 1985, at 17BM (explaining that after various

setbacks the year before, including two disastrous fires, the com-

pany was hoping for a turnaround and was banking heavily on

CTN). (For a pictorial history of the company, see Scandinavian

World Cruises—SeaEscape, <http://www.simplonpc.co.uk/

SeaEscape.html>.)

By 1987, Florida had six CTN vessel s. Their right to

operate, however, had become an iss ue due to a pair o f dueling

opinions issued by Panama City State Attorney Jim Appl eman

and his Pensacola counterpart Curtis Golden. While Apple-

man thought the c ruises were lawful, Golden disagreed. As a

result, SeaEscape approached Senator Gwen Margolis (D-

North Miami Beach) and got her to champion a bill confirming

the industry’s legality. See Tyler Bridges, Mysterious Loop-

hole Launched Florida Fleet, Miami H erald,Nov.23,1997,

at 17A (explaining that after the bill was vetoed by Governor

Bob Martinez, Margolis was able to slip its provisions into an

unrelated one dealing with bingo). See also Fla. Sen. J.,

May 28, 1987, at 486, availabl e at <http://archive.flsenate

.gov/data/Historical/Senate%20Journals/1 980s/1987/27-

452TO49805_28_87.PDF> (text of Margolis’s amendments to

the bingo bill).

Although the new law certainly helped, see David Lyons,

The War of the One-Day Cruise: A Spirited Battle for a

Growing Market, Miami Herald, June 27, 1988, at 7BM,

questions remained due to the GSA. When Con gress addressed

them in 1994, the industry took off like a rocket. See Julie Kay,

Putting Cards on a Tabl e at Sea: Gambling is Main Activity in

Burgeoning ‘‘Cruises to Nowhere,’’ Miami Herald, Jan. 19,

1997, at 1J. See also infra note 9.

The 1994 changes had a second effect: lower entry barriers.

Previously, to avoid prosecution for running a ‘‘gambling ship,’’

operators had to provide extensive non-gambling activities. Not

only did such options take money, they required a full-sized

vessel. By allowing operators to offer just gambling, the GSA

dramatically slashed costs and made it possible for even the

most thinly capitalized entrepr eneur to jump in. This created a

sharp clash between the existing ‘‘big ships’’ and the upstart

‘‘little boats’’:

By late 1995 there were nine day-cruise vessels in South

Florida, with half a dozen docked at ports in Miami,

Fort Lauderdale and West Palm Beach. Five were large

boats, 400 feet or longer, capable of carrying 600 to

1,500 passengers.

Now there are six afloat, and only two large ones. Only

the two big gest ships dock at major ports: New Sea

Escape’s Ukraina at Port Everglades, which calls itself

‘‘the only big ship in town,’’ and the Viking Princess at

the Port of Palm Beach.

The large ships that used to dominate the market have

been replaced by smaller vessels—‘‘floating crap tables,’’

one executive called them—that usually carry only 100–

200 passengers and are designed solely for gambling.

These vessels are generally less than 200 feet long and

weigh less than 300 tons, said Louis Perez, deputy direc tor

of the Port of Palm Beach.

‘‘That’s a cork that bobs in the water,’’ Perez said.

Those smaller boats have apparently drawn gamblers

away from all three of South Florida’s major ports,

which have seen a significant decline in the number of pas-

sengers taking gambling cruises.

Said [Nikki Grossman, president of the Greater Fort

Lauderdale Convention and Visitors Bureau]: ‘‘I think

there is a limited number of people who want to do this,

and the smaller ships are sharing—I hesitate to use the

word ‘stealing’—the same population of customers.’’ . .

The war among the gambling boats is a story of David

beating Goliath.

The smal ler boats don’t need a wide berth or a port pilot

and they do not pay the port’s dock and wharfage rates.

Two years ago, Discovery Cruise Lines was the largest

casino boat firm in South Florida with two cruise-to-

nowhere ships. It is down to one ship now, after a fire on

its other ship last year, and makes only day-long trips to

Grand Bahama.

‘‘We’re not a gambling boat,’’ says Burt Beer, Discovery

vice president. ‘‘We’re more of a vacation trip company now.’’

Beer said Discovery cannot compete with the cheaper pri-

ces charged by the smaller boats.

‘‘In some cases, they charge nothing,’’ Beer said. ‘‘That’ s a

little bit below my costs. ’’

SunCruz charges a maximum of $15; New Sea Escape

charges $29.95.

SunCruz, which has a vessel that docks in Hollywood and

four other ships in Florida, lures players with a liberal comp

system. [Greg Karan, the firm’s vice president] said 90 percent

of the gamblers on the ship pay nothing because they give the

boat enough action to justify a free trip.

SunCruz can afford such tactics because owner Gus

Boulis, a prominent Hollywood developer, owns just

about everything related to the ship—including the dock

space. Karan says other gambling ships have to divide

their profits among various sub-contractors, who provide

the food an d run the casino. .

Meanwhile, the large gambling ships are focusing on

cruises to the Bahamas, where they can charge more and

make more money because gamblers stay in the casinos longer.

Discovery goes to Freeport every day. New Sea Escape

makes one cruise a week to the islands and is negotiating

with Port Everglades to add another ship for Bahamas-

only cruises.

Port officials and casino ship executives said they ex-

pect smaller boats to continue to dominate the cruise-to-

20 JARVIS

(footnote 5 continued) nowhere market. They also expect

more failures in the business.

Lane Kelley, Going Nowhere: Once-Popular Floating Casinos

Are No Longer a Sure Bet to Succeed in South Florida, S. Fla.

Sun-Sentinel, Oct. 19, 1997, at 1B. See also C. Dean Hof-

meister, Day Cruises and Gambling Boats Are Not the Same,

Miami Herald, Dec. 7, 1997, at 2L (letter to the editor).

In describing the different options available, one popular

guidebook advised readers:

There are a variety of boats in operation ranging from St.

Petersburg’s 2,000-passenger Ocean Jewel cruise ship all

the way down to the yacht-sized SunCruz I casino boat

in Key Largo which carries 149 passengers.

Generally, you will find that the larger ships have more

of a variety of things to do besides the gambling, but the

cost will be a little higher because of added port/service

charges. Most of the ships that sail from the major ports,

such as Port Everglades [Fort Lauderdale], Port of Palm

Beach or Port Canaveral will add port/service charges to

the quoted cruise price. Usually, there is also a charge to

park your car at the large ports.

Most of the smaller boats which don’t dock at the large

ports don’t have port/service charges added to their cruise

prices. Also, most of the smaller boats offer free park-

ing. .

[Almost] all Florida casino boats offer: blackjack,

craps, roulette, slots and video poker. Some casinos also

offer: mini-baccarat (MB), poker (P), pai gow poker

(PGP), three-card poker (TCP), Caribbean stud poker

(CSP), let it ride (LIR), big 6 wheel (B6) and bingo (BG).

Each casino boat sets its own minimum gambling age:

on some boats it’s 21 and on others it’s 18. [In accordance

with Florida state law, the] minimum drinking age on all

boats is 21. Due to security restrictions, you must present

a photo ID at all casino boats or you will not be allowed to

board.

American Casino Guide 2006, at 169 (Steve Bourie ed.,

2006).

Without question, Florida’s most unusual gambling boat was

the Bounty Hunter, a 40-foot fishing boat in Naples that had just

one blackjack table:

[Russ Murphy III] bills his floating card parlor as ‘‘the

world’s smallest casino.’’ But with a minimum bet of

$20 and a $300 maximum wager, the stakes are anything

but small.

‘‘We’re going after the avid blackjack player,’’ he said.

‘‘For the people who want to play $5 hands or the slots,

that’s not us.’’ . .

As for his boat’s size? Murphy figures his modest oper-

ation is a virtue, or at least not a hindrance.

‘‘If a guy’s a real gambler, he doesn’t care where he’s

playing,’’ Murphy said.

Alan Scher Zagier, Small Floating Casino Competes with Big-

ger Boats, Naples Daily News, Mar. 15, 2001, at D1.

In 1997, the Miami Herald published a long and unflattering

profile of Florida’s CTN operators. See Tyler Bridges, Welcome

to Florida, Home of America’s Largest Unregulated Gambling

Industry: Mysteries at the Helm, Miami Herald, Nov. 23,

1997, at 1A. Two weeks later, the St. Petersburg Times

demanded that the Florida Legislature take action:

Three times in the last 20 years, Florida voters have

rejected casino gambling. Yet casino-style gambling flour-

ishes from ports in Tarpon Springs, Madeira Beach and

other wat erfront cities throughout the state. On its face,

that inconsistency should anger Flo ridians enough to pres-

sure state government to try to shut down the casino

cruises. But the state’s failure to adequately regulate and

tax the industry is even more alarming.

A recent investigation by the Miami Herald detailed the

astounding lack of scrutiny of the roughly two dozen gam-

bling boats operating out of Florida ports. The state does

not know for sure who owns the boats. It does not license

the operators, check to see whether organized crime is in-

volved, determine whether the games are rigged, or ensure

the boats are not laundering money. .

Searching public records, the newspaper revealed de-

tails about several cruise ship officers and companies

that could make it difficult for them to win a gambling

license—if Florida issued gambling licen ses. Among its

findings:



Steven C. Squitiro, vice president of Tarpon Springs

Casinos Cruises, filed bankruptcy in 1995. He listed

debts of more than $400,000 and an average annual in-

come of $50,000. In 1997, he invested $100,000 in the

cruise ship. Squitiro would not tell the newspaper

where he got the money. He would have to reveal that

information to get a gambling license in most instances.



Europa Cruises Corp. operates one of its ships from Ma-

deira Beach. Ernest G. Walter, one of the co mpany’s

major stockholders, was convicted of bank fraud this

year in Austria. Regulators usually have a problem

with convicts being major casino stockholders.



Empress Cruise Lines operates boats from Treasure

Island and Clearwater and has filed for bankruptcy. It

has been accused in that court case of keeping two

sets of books. Its attorney denies the charge.

. .

The simple solution to this festering problem is for

the Legislature to repeal a legal loophole it created a de-

cade ago and ban the casino ships. That isn’t likely. A

lawsuit filed by Attorney General Bob Butterworth

and the St. Johns County sheriff that sought to ban

slot machines on the cruise ships has been dismissed be-

cause the business there folded. Perhaps Butterworth

can find another legal avenue to pursue.

In the meantime, Florida cannot afford to keep pre-

tending casino cruise ships do not exist. If this state is

stuck with them, it ought to at least tax and regulate

the boats as heavily as casinos are in other states.

‘‘Unregulated Gambling,’’ St. Petersburg Times, Dec. 8,

1997, at 12A. Of course, the anonymity enjoyed by the CTN in-

dustry also attracts players. See, e.g., Ron Scherer, No Scrutiny

of High Rollers on High Seas, Christian Sci. Monitor, Feb.

19, 1998, at 1.

In 1999, Representative Frank R. Wolf (R-Va.), alarmed by a

proposal to put a gambling boat in Virginia Beach, introduced

the Cruises-to-Nowhere Act (H.R. 316). See 145 Cong. Rec.

E25, E26 (daily ed. Jan. 7, 1999). It directed that nothing in

federal law was to be interpreted as preempting states in

their efforts to regulate CTN. See Andy Crain, Bill Would

Allow States to Pull Plug on Gambling Boats, Sarasota

Herald-Trib., Feb. 21, 1999, at 14A. Unsurprisingly, the

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 21

founder Konstantinos ‘‘Gus’’ Boulis—was killed in

a mob hit in February 2001.

Because of t he paucity of data, a recent arti -

cle in this journal cited 1996 statistics a bout Flor-

ida’s CTN industry in a way that made it seem

the state’s casino boats were thriving: ‘‘Since the

1996 law was passed, a large number of ships

have begun operations off Florida and also in the

Northeast. . Over 22 ships operate off Florida,

generating collective revenues well over $200 mil-

lion a year.’’

In fact, Florida’s CTN industry

looks nothing like it did in 1996. As of January 1,

2017, the state is down to just three gambling

ships.

(footnote 6 continued) proposal encountered strong resistance,

with opponents claiming it would cost jobs. See Laurence

Arnold, Florida Cruise Industry, Ship Builders Oppose Float-

ing Casino Ban, Stuart News, July 29, 1999, at A6. As a re-

sult, it did not make it out of commit tee. See <https://

www.govtrack.us/congress/bills/106/hr316>.

Boulis, having made a fortune as the founder of Miami Subs, a

fast food chain, started SunCruz in 1994 by buying yachts and

turning them into casino boats. See John Lundin, Holly-

wood Gambler: The Gus Boulis Story (2004).

In 2005, three men were char ged with killing Boulis: Anthon y

‘‘Little Tony’’ Ferrari, James ‘‘Pudgy’’ Fiorillo, and Anthony ‘‘Big

Ton y’’ Moscatiello. In 2012, Fiorillo pleaded guilty to conspiracy

and became a cooperating witness. After testifying against Ferrari

and Moscatiello, Fiorillo was sentenced to time served and set free.

See Rafael Olmeda, Setup Man in Boulis Case Gets Time Served

and Is Free, S. Fla. Sun-Sentinel, July 18, 2015, at 1B. In 2013,

Ferrari was convicted of first-degree murder and sentenced to life

imprisonment. See Erika Pesantes, ‘‘Little Tony’’ Gets Life in Bou-

lis Murder, S. Fla. Sun-Sentinel, Dec. 20, 2013, at 1A. In 2015,

Moscatiello suf fered the same fate. See Rafael Olmeda, Final

Defendant in Miami Subs Murder Gets Life Term, S. Fla. Sun-

Sentinel, Sept. 18, 2015, at 1A.

Boulis’s execution took place five months after he sold Sun-

Cruz for $147.5 million to Jack Abramoff, a W ashington, D.C.

lobbyist, and Adam Kidan, a New York attorney. The sale was ne-

cessitated by the fact that Boulis, as a foreign national, could not

legally own American-flagged vessels. As part of the deal, Boulis

retained an undisclosed 10% interest in SunCruz. The trio’s rela-

tionship quickly soured due to Abramoff and Kidan’s inability to

fulfill their end of the bargain. When Boulis threatened to take

back the company, he was murdered (Moscatiello, a member of

the Gambino crime family, was an associate of people Abramoff

knew). Although both Abramoff and Kidan ev entually served time

in federal prison, neither was prosecuted for Boulis’ s death. For a

further look at Abramof f and Kidan, see, e.g., the 2010 documen-

tary Casino Jack and the United States of Money; the 2010

feature film Casino Jack (starring Kevin Spacey as Abramof f

and Jon Lovitz as Kidan); and Abramoff’s 2011 autobiography,

Capitol Punishment: The Hard Truth About Washington

Corruption from America’s Most Notorious Lobbyist.

Following Boulis’ s death, SunCruz filed for bankruptcy. See

Jeff Shields, SunCruz Delays Suits with Bankruptcy Filing, S.

Fla. Sun-Sentinel, June 23, 2001, at 8B. After years of acrimo-

nious litigation, see, e.g., In re SunCruz Casinos, LLC, 298 B.R.

821 (Bankr . S.D. Fla. 2003), the business was sold to Oceans

Casino Cruises (headed by Boulis’s nephew Spiros Naos) for

$36.1 million. See Suncruz Sale Completed, Miami Herald,

Apr. 13, 2004, at 1C. Unable to duplicate its previous success,

the company folded in 2009. See Wayne T. Price, It’s Chapter 7

for SunCruz, Fla. Today (Melbourne), Dec. 30, 2009, at C6.

William Thompson, Navigating the Tides of Fortune: Wagers

on the Sea,20Gaming L. Rev. and Econ. 743, 762 (2016)

(footnotes omitted). As Thompson indicates, see id. at n.299,

this statement is taken from Anthony Cabot and Robert Faiss,

Cruises to Nowhere, in Gambling in America: An Encyclo-

pedia of History, Issues, and Society (William N. Thomp-

son ed., 2d ed. 2015).

It should be noted that the 1996 law referenced by Thompson

(and Cabot and Faiss) has nothing to do with Florida or CTN.

Instead, it concerned shipboard gambling in Alaska and riverboat

gambling in Indiana. See Mike Dorning and Mary Jacoby , Indi-

ana’s Riverboats Get Leave to Sail, Chi. Trib., Oct. 13, 1996, at 2.

Unfortunately, year-by-year statistics for the industry do not exist.

Indeed, in 1996, as CTN were surging in Florida, state off icials ad-

mitted they had no idea ‘‘exactly how many cruise ships leave

Florida ports to sail three miles offshore and open up the slot ma-

chines and blackjack tables.’’ Tyler Bridges, Cabinet Calls for a

Ban on State’s Gaming Vessels, Miami Herald, Sept. 11,

1996, at 1BR. Likewise, the 2013 Gambling Impact Study,

which the Florida Legislature paid the Spectrum Gaming Group

$400,000 to prepare, could do no better than say: ‘‘Statewide,

there are also a handful of casino cruises departing daily from

ports throughout the state, some of which provide overnight

cruises to the Bahamas and others which solely provide day-cruise

excursions into international waters for gaming. The casino cruise

industry in Florida is in a constant state of flux, generally down-

ward. Ten years ago there were far more casino cruises in opera-

tion, but the industry niche has not fared well competing against

land-based operations.’’ Spectrum Gaming Group, Gambling

Impact Study 100 (Oct. 28, 2013), available at <http://www.leg

.state.fl.us/GamingStudy/docs/FGIS_Spectrum_28Oct2013.pdf>.

Nevertheless, based on an examination of the figures

reported in published sources (primarily contemporaneous

newspaper stories), it is possible to get a rough idea of how

many CTN were operating in Florida at different times:

It is much tougher to find numbers after 2008 for two reasons: (a)

by 2007, reporters had shifted their atte ntion to the casinos run by

the Seminole Indian tribe; and, (b) in 2009, the Day Cruise Asso-

ciation, the C TN’s trade group, disbanded. See <http://search

.sunbiz.org/Inquiry/Cor porationSearch/ByName> (search of state

corporate records indicating that the organization was founded in

1994 7 (beginning of year); 13 (end of year)

1995 15

1996 20

1997 22

1998 26

1999 30

2000 28

2001 20

2002 18

2003 17

2004 17

2005 13

2006 10

2007 14

2008 14

22 JARVIS

II. DEATH OF AN INDUSTRY

It is not hard to pinpoint the factors that have

led to the demise of Florida’s CTN industry.

Between F ebrua ry 2007 and September 2008,

four unprecedented events combine d to deliver a

fatal blow:

1. In February 2007, oil prices suddenly be gan spiral-

ing out of control. During the next 18 months, the

cost of marine diesel fuel nearly doubled.

2. In November 2007, after 16 years of conten-

tious negotiations, Florida and the Seminole

Indians signed their first gambling compact.

In exchange for a share of its profits, the tribe

received: a) exclusive statewide baccarat and

blackjack rights; and, b) exclusive slot ma-

chine rights in 65 of the state’s 67 counties.

As a result, the tribe’s casinos became Florid-

ians’ preferred places to gamble

and, in rel-

atively short order, put out of business

SeaEscape (2008), SunCruz (2009), Palm

(footnote 9 continued) 1994, dropped the word ‘‘Florida’’ from its

name in 1999, and was administratively dissolved in 2009).

Neve rtheless, I have come up with these additional counts:

According to one commentator, CTN in Florida between 1984

and2007tookplaceon67differentvessels.See Donald D.

Spencer, History of Gambling in Florida 71–90 (2008).

Because Spencer missed a few ships (e.g., Amerikanis, Southern

Elegance), and taking into account the post-2007 ships, the total

now is likely 80–90. Coming up with a more definiti ve number is

diff icult for several reasons, including how frequently ships

changed their identities. The Victory II, for example, currently sails

out of Jacksonville. See infra notes 62–67. During earlier incar-

nations, she was known as the Aquasino (both with and without

SunCruz’s name as a prefix), Atlantic,andMax I and was home-

ported in Ke y West, Little Ri ver, L ynn (Massachusetts), Miami

Beach, and Myrtle Beach. See, e.g., Horry County v. Aquasino

Partners of South Carolina, LLC, 2014 WL 2589825 (S.C. Ct.

App. 2014); Thor Jourgens en, Aquasino Puts into Lynn Port,

Daily Item (Lynn, MA), May 16, 2013, at A1; Frank Houston,

More Tales from the Aquasino, Miami New Times,Nov.

15, 2007, <http://www.miaminewtimes.com/news/more-tales-

from-the-aquasino-6524363>; Employees Learn Ropes on

Keys Gambling Ship, Fla. Today (Melbourne), Nov. 8, 1997,

at 1B.

By the time these began to occur, the industry already was

suffering. See, e.g., Emily Witt, The Boat to Perdition, Miami

New Times, Jan. 19, 2006, <http://www.miaminewtimes.com/

news/the-boat-to-perdition-6337763> (describing 2005 as ‘‘The

Year of Sinking Dangerously’’); Scott Blake, Passenger Counts

Down for Local Gambling Ships, Fla. Today (Melbourne),

Nov. 3, 2005, at C1; Patrick Danner, Gambling Ships Hit

Troubled Waters, Miami Herald, Feb. 26, 2005, at 1A

[hereinafter Troubled Waters]. As these sources report, the in-

dustry had been hit hard by: a) a 2004 constitutional amend-

ment authorizing slots at Broward and Miami-Dade’s pari-

mutuel facilities; b) the 2004 opening of the Seminoles’ flag-

ship casinos in Hollywood and Tampa; and, c) the 2004 and

2005 hurricane seasons, which saw six storms batter Florida

(Charley, Frances, Ivan, Jeanne, Katrina, and Wilma), resulting

in numerous cancelled cruises and sharply higher insurance

premiums.

See U.S. Energy Information Administration (EIA), Weekly

East Coast No 2 Diesel Ultra Low Sulfur (0–15 ppm) Retail

Prices, EIA, <https://www.eia.gov/dnav/pet/hist/LeafHandler

.ashx?n=PET&s=EMD_EPD2DXL0_PTE_R10_DPG&f=W>

(documenting a jump in prices from $2.45 per gallon in Feb-

ruary 2007 to $4.79 per gallon in July 2008). For a further

discussion, see James D. Hamilton, Causes and Consequences

of the Oil Shock of 2007–08, Brookings Papers on Eco-

nomic Activity (Spring 2009), available at <https://www

.brookings.edu/wp -content/uploads/2016/07/2009a_bpea_

hamilton-1.pdf>. See also World Oil Market Chronology from

2003, Wikipedia: The Free Encyclopedia, <https://en

.wikipedia.org/wiki/World_oil_market_chronology_from_2003>.

See Robert M. Jarvis, The 2007 Seminole-Florida Gambling

Compact,12Gaming L. Rev. 13 (2008) [hereinafter 2007

Compact]. The agreement was scuttled after the state’s legisla-

tors, having been left out of the negotiations, successfully chal-

lenged the deal in court. See Florida House of Representatives

v. Crist, 999 So. 2d 601 (Fla. 2008), cert. denied sub nom. Sem-

inole Tribe of Fla. v. Florida House of Representatives, 555 U.S.

1212 (2009). As a result, a new compact had to be hammered

out with their participation. See Mary Ellen Klas, Crist Signs

Bill for $1 Billion Gambling Pact, St. Petersburg Times,

Apr. 29, 2010, at 5B. In the interim, the Seminoles, claiming

that the original agreement was still in effect, proceeded with

their expansion plans. See Allison Sirica, Note, A Great Gam-

ble: Why Compromise is the Best Bet to Resolve Florida’s In-

dian Gaming Crisis,61Fla. L. Rev. 1201, 1204 (2009).

See 2007 Compact, supra note 12. Broward and Miami-Dade

counties were ‘‘carved out’’ due to a 2004 constitutional amend-

ment that had granted their pari-mutuel facilities the right to

have such devices. See Fla. Const. art. X, § 23. See also

Alan B. Koslow and David S. Romanik, Gaming at Florida

Pari-Mutuels: Racinos Are a Sure Bet for the Sunshine State,

10 Gaming L. Rev. 107 (2006).

See Jaclyn Giovis, At Sea, Long Odds: Challenges Mount for

S. Florida Casino Ships, S. Fla. Sun-Sentinel, Aug. 17,

2008, at 1D (‘‘When blackjack arrived at the Seminole Hard

Rock Hotel and Casino in late June, cruise-to-nowhere boats

lost their claim as the only venue to offer local residents one

of the most popular casino card games. It’s proving to be a

tough blow for these ships, especially on top of other chal-

lenges: stiffer competition for slots players, high fuel prices, a

slow economy and rough weather during hurricane season.’’).

2009 10

2010 7

2011 6

2012 6

2013 5

2014 5

2015 6

2016 4

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 23

Beach Princess (2010), and Discovery

(2011).

3. In July 2008, Florida began prohibiting casino

boats from dumping their wastewater at sea.

Under this legislation, CTN operators either

had to start using costly pump-out facilities

in port or install, at even greater expense,

on-board treatment systems.

4. In September 2008, Lehman Brothers, the

New York City financial giant, filed for bank-

ruptcy, thereby setting in motion the Great

Recession. In response, Florida’s economy,

See Nick Sortal, Rolling the Dice on the High Seas, S. Fla.

Sun-Sentinel, Jan. 4, 2013, at 5 (Showtime). Although all

four companies succumbed to the Seminoles, each did so in

its own way:



SeaEscape, out of money, stopped sailing in August

2008. See Jaclyn Giovis, SeaEscape Plans to Depart:

Company Expected to Leave Port Everglades After 21

Years, S. Fla. Sun-Sentinel, Aug. 12, 2008, at 1D.

As it scrambled to find fresh financing, its crew,

which had not been paid in months, decided to take ac-

tion and had the ship (Island Adventure) arrested. See

Jaclyn Giovis, U.S. Can Seize Gambling Ship: Court

Rules in Favor of Unpaid Crew Members, S. Fla.

Sun-Sentinel, Aug. 23, 2008, at 1D. This made it im-

possible for the company to attract new investors and led

to a judicial auctioning of the ship in October 2008.

Glenn Straub, an eccentric Palm Beach businessman,

won the bidding by agreeing to pay $3.6 million; after-

wards, he told reporters he planned to steer the vessel

‘‘away from its gambling past and position it . as an en-

tertainment venue.’’ See Jaclyn Giovis, Handshake Deal

for Casino Ship Can’t Be Finalized: SeaEscape Will

Remain with the Auction’s High Bidder and Not Be

Resold to the Runner-Up, S. Fla. Sun-Sentinel, Oct.

23, 2008, at 1D. When nothing came of this idea (or an-

other one to turn the vessel into a floating hospital), the

ship was scrapped in 2011. See Ship Demolition Report,

Ship Scrapping (Dec. 13, 2011), <http://mersey

shippingblogspot.com/2011/12/ship-demolitions-as-of-

13122011.html>.



Oceans Casino Cruises, the parent company of SunCruz,

filed for liquidation in December 2009. See supra note 7.

At the time of its demise, it had three locations: Jack-

sonville (Suncruz VII), Myrtle Beach (Suncruz VIII), and

Port Canaveral (Suncruz XII). The Suncruz VII became a

Savannah gambling ship (Diamond Royale), failed as

such, was abandoned, and in 2014 was sold at auction for

$100,000 to a man looking for a houseboat. See Tyrone

Richardson, Abandoned Casino Ship Sells for $100,000,

Post and Courier (Charleston, SC), Apr. 3, 2014,

available at <http://www.postandcourier.com/business/

abandoned-casino-ship-sells-for/article_dddce1d2-59e1-

5598-ace2-eea173e9e185.html>. The Suncruz VIII be-

came the New York City excursion boat Hornblower

Infinity. See <http://www.st.nmfs.noaa.gov/pls/webpls/

cgv_pkg.vessel_id_list?vessel_id_in=977138> and https://

www.hornblo wer.com/port/yacht/ny +41%3Bjsessionid =

62B5963996621295E01C9C821B69EA97>. Lastly, the

Suncruz XII is still in Port Canaveral, where she is sailing

as the gambling ship Victory I. See infra notes 62–67 and

accompanying text.



Palm Beach Princess filed for bankruptcy on Christmas Eve

2009. See Paul Quinlan and Jane Musgra ve, Princess Back

in Rough Waters: Palm Beach Princess Lists in Bankruptcy

Court, Palm Beach Post, Dec. 25, 2009, at 1C. In April

2010, its eponymous ship, ordered by a judge to v acate its

berth at the Port of Palm Beach, sailed to Freeport. See

Christine Stapleton, Palm Beach Princess, Bankrupt and

Listing, Limps Out of Port for Last Time, Palm Beach

Post, Apr. 8, 2010, at 1A. There, it waited while its owners

tried to find work for it as temporary housing. See Ana M.

Val des , ‘ ‘Princess’’ Facing 1 of 2 Fates: Relief Mission or

Scrap Heap, Palm Beach Post, Aug. 7, 2010, at 2B.

When no takers could be found, the ship was scrapped

in 2011. See Palm Beach Princess, Wikipedia: The

Free Encyclopedia, <https://en.wikipedia.org/wiki/Palm_

Beach_Princess>.



Discovery Cruise Line had the most orderly wind-do wn,

announcing in July 2011 that it planned to stop sailing after

Labor Day . See Arlene Satchell, Discovery Cruise Line to

End Service Sept. 6; Day-Trip Operator Cites High Oper-

ating Costs, Lack of Profitability, S. Fla. Sun-Sentinel,

July 28, 2011, at 1D. Although attempts were made to find a

buyer for its ship (Discovery Sun), nothing material-

ized and the vessel was scrapped in 2012. See Ship

Demolition Report, Ship Scrapping, Feb . 13, 2012, <http://

merseyshipp ing.bl ogspot.com/2012/0 2/ship-demolitio n-

report-1322012.html>.

Ironically, early in their quest for a compact the Semi-

noles insisted that the state’s failure to take action against

the CTN industry meant it had implicitly authorized

tribal gaming. See Seminole Tribe of Fla. v. State of Fla.,

1993 WL 475999, at *13–*14 (S.D. Fla. 1993) (rejecting the

argument).

Environmental activists, led by the Surfrider Foundation, had

campaigned vigorously for such legislation. See, e.g., Jeff

Schweers, Surfers Heckle Gambling Ship, Fla. Today (Mel-

bourne), Sept. 24, 2007, at B1; Dianna Cahn, Protest’s

Focus: Gaming-Ship Waste—Activists Want Halt to Dumping

Near Shore , S. Fla. Sun-Sentinel, Jan. 28, 2007, at 3B. See

also Scott Blake, Allen Wants Ships to Stop Offshore Dumping ,

Fla. Today (Melbourne), July 22, 2005, at A1.

See Robert M. Jarvis, 2007–2008 Survey of Florida Gambling

Law,33Nova L. Rev. 231, 238–40 (2008) (discussing the

‘‘Gambling Vessels/Clean Ocean Act,’’ now codified at

Fla. Stat. § 376.25). The Florida Department of Environmen-

tal Protection (DEP) maintains a detailed web page about the

statute. See DEP’s Gambling Vessel Registration Program,

<http://www.dep.state.fl.us/water/wastewater/gamb-vessel.htm>

[hereinafter DEP Registration Program]. See also E-mail from

Sherry Bowersox, P.E., Wastewater to Wetlands Coordinator,

Domestic Wastewater Program, Florida Department of Envi-

ronmental Protection, to the author, dated Dec. 22, 2016, at 12:29

p.m. (copy on file with the author) (explaining that two of

Florida’s three remaining gambling ships pump out in port while

the third has an approved on-board system).

24 JARVIS

which already was in the doldrums, com-

pletely collapsed.

It is an open question whether Florida’s CTN in-

dustry would have survived if one or more of these

calamities had not occurred. Even under the best of

circumstances, running a CTN operation is difficult

and expensive.

First, casino boats, although typically thought

of as casinos that happen to be on vessels, actually

are vessels that happen to have casinos.

Thus, in

addition to gaming experience, operators need

maritime experience to be able to handle, inter

alia, allisions, collisions, fires, explosions, medi-

cal emergencies, overboards, sinkings, and strand-

ings.

See, e.g., Florida TaxWatch, The Current Recession in Flor-

ida: Comparative Information and Data on the Worst Eco-

nomic Downturn Since the 1930s, FloridaTaxWatch.org

(Aug. 2009), <http://www.floridataxwatch.org/resources/pdf/

eco32.pdf> (pointing out that a) Florida’s economy had begun

declining nine months before the rest of the country, and b) the

Great Recession’s toll in Florida was 250% more severe than in

other states).

Florida’s CTN industry has never operated ‘‘under the best of

circumstances.’’ Almost from the beginning, Florida Attorney

General Bob Butterworth engaged in an all-out war against

the industry. See, e.g., Butterworth v. Chances Casino Cruises,

Inc., 1997 WL 1068628 (M.D. Fla. 1997) (attempt to have the

Royal Princess declared a public nuisance); State, Bd. of Trust-

ees v. Day Cruise Ass’n, Inc., 794 So. 2d 696 (Fla. Dist. Ct.

App.), rehearing denied, 798 So. 2d 847 (Fla. Dist. Ct.

App. 2001), review denied, 823 So. 2d 123 (Fla. 2002) (attempt

to keep CTN operators from anchoring in state waters); Butter-

worth v. Tropic Casino Cruises, Inc., 796 So. 2d 1283 (Fla. Dist.

Ct. App. 2001) (attempt to close down SunCruz using a ques-

tionable interpretation of the state’s gambling laws); Butter-

worth Targets Gambling Cruises, Stuart News, Feb. 4,

2000, at B6; Kevin Metz, Butterworth Targets Gambling

Ships, Tampa Trib., July 5, 1996, at 6; Florida Cabinet, Meet-

ing Transcript, at 99–123 (Sept. 10, 1996), available at <http://

www.myflorida.com/myflorida/cabinet/agenda96/0910/trans

.html> (extensive criticism by Butterworth of the CTN indus-

try). See also infra notes 25–26 and accompanying text (attempt

to drive up operators’ costs by increasing their required sailing

distances).

In addition to the industry and its allies (mainly labor unions,

port authorities, and shipyards), Butterworth’s efforts received

strong pushback from many of the state’s senior citizens:

Gov. Lawton Chiles and the Florida Cabinet wanted to ban

the boats but concluded last month that a federal law

would prevent that. Instead, they urged the Legislature

to declare the boats illegal.

But efforts by the Legislature—led by Rep. Jim King, a

Republican from Jacksonville—to take such action failed

last year, when lawmakers were swamped with letters and

postcards. Many of the postcards originated in Dade and

Broward, including one from a condominium association

at Century Village in Deerfield Beach which stated a

ban on day cruises would have a ‘‘devastating’’ effect on

the lives of senior citizens and be ‘‘disastrous’’ to Florida’s

economy. .

On a recent Wednesday, the SunCruz Casino’s daytime

cruise was packed, mostly with retirees. Ronnie Greenhut

of Plantation, who says she loses $500 on each of her

twice-weekly visits to the SunCruz, was among them.

A card-ca rrying VIP member of SunCruz, Greenhut

said she was unhappy at the Legislature’s efforts to ban ca-

sino ships.

‘‘I think it’s terrible. What else is there left for people to

do?’’

Eileen Galaton of Coral Springs and Tobye Saltz man of

Sunrise, ready for an afternoon aboard the SunCruz, also

decried the Legislature’s plan.

Saltzman, whose last visit to the SunCruz was Aug. 14,

said ‘‘it would break my little old heart’’ if the Legislature

banned the ships.

Galaton, who also plays bingo at the Seminole reserva-

tion near Hollywood, had this message for the Legislature:

‘‘Tell them to butt out.’’

Julie Kay, High Rollers Head for the High Seas, Miami Her-

ald, Sept. 29, 1996, at 10SE. See also Steve Bousquet, Casino

Ships Win a Hand in Capitol, Miami Herald, Mar. 22, 1996,

at 2BR (‘‘The [Regulated Industries’ lottery and gaming] sub-

committee chairman, Rep. Ben Graber, D-Coral Springs, said

he recently spoke to about 300 members of a women’s club

at Ramblewood East condominiums in Pompano Beach.

When he asked for a show of hands for support of cruises to no-

where, Graber said, ‘I’d say 295 hands went up.’’’).

See Scott Blake, Gambling with Passenger Safety, Fla.

Today (Melbourne), Nov. 28, 2004, at 1 (quoting U.S. Coast

Guard Marine Safety Officer Lt. Patrick Eiland).

See, e.g., National Transportation Safety Board (NTSB),

Marine Accident Report NTSB/MAR-06/02, NTSB.gov (Apr.

4, 2006) (‘‘Fire On Board U.S. Small Passenger Vessel

Express Shuttle II, Pithlachascotee River, Near Port Richey,

Florida, October 17, 2004’’), available at <http://www.ntsb

.gov/investigations/accidentreports/reports/mar0602.pdf>;Mary

Kelli Palka, Coast Guard Rescues 5 Men from Disabled Gam-

bling Ship, Fla. Times-Union (Jacksonville), Mar. 9, 2008, at

B1 (Suncruz IX); Trenton Daniel, Casino Boat: Search for

Missing Crewman Called Off, Miami Herald, Nov. 15, 2007,

at B1 (SeaEscape overboard assistant cook); Caren Burmeister,

Suncruz Rescues OK, Coast Guard Says, Fla. Times-Union

( Jacksonville), Oct. 12, 2005, at L1 (overboard passenger);

Adam Emerson, Ocean Jewel’s Shuttle Bumps Bridge, Tampa

Trib., Apr. 25, 2005, at 4 (Metro); Vicky Agnew et al., Fire

Ends Gambling Ship Trip; SunCruz Patrons Startled, but Safe,

S. Fla. Sun-Sentinel, May 17, 2004, at 1A; Richard Raeke,

Passengers Save Boat Captain’s Life, St. Petersburg Times,

Apr. 13, 2004, at 1 (Pasco Times) (SunCruz tender captain—

heart attack); Andrew Marra, Officials Say Man Jumped Off

Ship, Palm Beach Post, Mar. 24, 2004, at B1 (overboard Palm

Beach Princess passenger); Hannah Simpson, Ship Fire Can-

cels Cruise of SeaEscape, Miami Herald, Apr. 15, 2003, at

6B; Ray Martinez, El Dorado Gambling Ship to Sail Again,

Stuart News, Nov. 27, 1999, at B1 (‘‘After running aground

earlier this week, the gambling ship El Dorado was cleared

Friday to sail again, the Coast Guard reported. An underwater

survey found no damage to the 140-foot cruise ship. . ’’);

Gamblers Stranded at Sea When Ship Malfunctions, St.

Petersburg Times, Oct. 24, 1998, at 8B (Casino Princesa—

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 25

Second, because of federal gambling laws, casino

boats can only open their casinos once they reach

‘‘international waters.’’

On Florida’s east coast,

this means transporting p layers at least three

miles offshore.

This number increases (due to

the state’s marine topography) to nine miles on

Florida’s west coast.

In 1997, relying on a re-

cently passed federal anti-terrorism law, Florida

Attorney General Bob Butterworth attempted to

impose a 12-mile requirement on both coasts.

He droppe d the idea, however, after a similar ef-

fort by New York C ity officials was quashed by

the c ourts.

Third, due to federal immigration laws, casino

boats must be flagged American and employ Amer-

ican crews.

They also must comply with stringent

U.S. Coast Guard safety regulations.

In addition,

like other vessels, casino boats must be li-

censed,

insured,

and put on a regular mainte-

nance schedule.

(footnote 21 continued) loss of steering power); Geoff Dutton,

Casino Ship Weathers Complaints, Daytona News-J., Nov.

24, 1997, at 1A (‘‘[R]eacting to situations such as [a passen-

ger’s] cardiac symptoms can be difficult, [SunCruz General

Manager Phil] Nolan said . ‘Without having a certified doctor

aboard, there’s not a whole lot we can do,’ Nolan said. As a

result, ‘we’ve turned the boat around quite a few times.’ It can

be a costly decision, but Nolan said it’s an accepted part of the

business. When cruises are cut short by a medical emergency,

passengers sometimes are reimbursed and other times the boat

returns to sea after unloading the sick passenger.’’); Arline

Giolli, Gambling to Blame for Ship That Went Bump in the

Night, St. Petersburg Times, Mar. 5, 1996, at 2 (Seminole

Times) (letter to the editor regarding an allision between the

Crown Empress and the Clearwater Pass Bridge). See also infra

note 35 (sinking, with loss of life, due to a hurricane).

Of course, land-based mishaps also occur. See, e.g., J.D.

Gallop, Gamblers Run into Bad Luck, Fla. Today (Mel-

bourne), Aug. 23, 2006, at 1B (breakdown of shuttle bus

transporting players to the Ambassador II).

See Robert M. Jarvis, Note, Gambling Ships: A Vessel Sailing

from the United States Cannot Legally Open Its Casino Until It

Reaches the High Seas,44J. Mar. L. and Com. 339 (2013). In

1998, Florida Attorney General Bob Butterworth filed com-

plaints against multiple Florida CTN operators, alleging that

they were opening their casinos prematurely. See Scott Hiaasen,

6 Casino Ships Accused of Allowing Illegal Gambling in State

Waters, Palm Beach Post , Dec. 2, 1998, at A1. The charges

later were settled. See Johnny Diaz, Gambling Ship Operators

Pay Fine, Agree to Revise Operations, Miami Herald, Aug.

18, 1999, at 7B.

See United States v. Florida, 425 U.S. 791 (1976). See also

Robert M. Jarvis, Territorial Waters: Florida’s Eastern Coastal

Boundary is the Greater of the Edge of the Gulf Stream or Three

Geographic Miles,34J. Mar. L. and Com. 351, 353 (2003).

See United States v. Florida, 363 U.S. 121 (1960).

See Tyler Bridges, Giving Gambling Ships a Push: Operators

Fear Losses if 12-Mile Limit is Imposed, Miami Herald, Oct.

22, 1997, at 5B.

See Lane Kelley, Gambling Ships Get Three-Mile Limit, S.

Fla. Sun-Sentinel, Dec. 9, 1997, at 8D, reporting on United

States v. One Big Six Wheel, 987 F. Supp. 169 (E.D.N.Y. 1997),

aff’d, One Bix Six Wheel, supra note 4, analyzed in Robert M.

Jarvis, Note, Gambling Ships: The Antiterrorism and Effective

Death Penalty Act of 1996 Does Not Extend the Territorial Sea

of the United States for Purposes of the Gambling Ship Act,29

J. Mar. L. and Com. 449 (1998).

This was not always true. As a result, several by-gone Florida

gambling ships (such as SeaEscape’s Island Adventure) were

flagged and crewed foreign to save money. However, as a result

of Bimini Superfast Operations LLC v. Winkowski, 994 F.

Supp. 2d 106 (D.D.C. 2014) (relying on M/V Southern Ele-

gance, INS Gen. Counsel Op. 91-4 ( Jan. 11, 1991), available

at 1991 WL 1185115), there now is no question that a foreign

vessel cannot engage in CTN. See further Johanna Jainchill,

Customs Says ‘‘Cruises to Nowhere’’ Were Never Legal,

Travel Wkly. ( June 21, 2015), <http://www.travelweekly

.com/Cruise-Travel/Customs-says-cruises-to-nowhere-were-

never-legal>; Tom Stiegho rst, ‘‘Cruises to Nowhe re’’ to End

in 2016, USA Today ( June 12, 2015), <http://www.usatoday

.com/story/cruiselog/2015/06/12/cruises-to-nowhere-to-end-in-

2016/71124092/>.

Failure to do so risks a loss of sailing privileges. See, e.g.,

Drew Dixon, Offshore Casino Temporarily Closed; Coast

Guard Finds ‘Safety Deficiencies’ on Mayport-based Gambling

Ship, Fla. Times-Union ( Jacksonville), May 26, 2015, at B3

(Victory II); Paul Quinlan, Coast Guard Sidelines Gambling

Ship Over Engine Repair, Palm Beach Post, Dec. 9, 2009,

at 1A (Palm Beach Princess); Scott Blake and Kaustuv Basu,

Gambling Ship Fails Another Inspection, Fla. Today (Mel-

bourne), Sept. 20, 2007 at 1C (Ambassador II); Willoughby

Mariano, Safety Problems Strand 2 Gambling Ships in Port,

Orlando Sentinel, Aug. 15, 2007, at B4 (Ambassador II

and Suncruz XII); Steve Huettel, Casino Ship Hits Inspection

Snag, St. Petersburg Times, Aug. 22, 2006, at 1D (Casino

Royale); Kevin Deutsch, Big Easy Casino Ship Loses Certifica-

tion, Stops Operating, Palm Beach Post, Feb. 4, 2006, at 3B;

Coast Guard Inspectors Shut Down SunCruz, Fla. Today

(Melbourne), Aug. 10, 2004, at 1 (Local) (Suncruz VII).

See, e.g., State v. Efthimiadis, 690 So. 2d 1320 (Fla. Dist. Ct.

App. 1997) (Vegas Express—lack of boating decal); Gambling

Ship Ready to Set Sail in July, Index-J. (Greenwood, SC), May

24, 1998, at 5A (Southern Elegance—approval of liquor license

application); Susannah A. Nesmith, State Closes Kitchen on

Gambling Ship, Palm Beach Post, Sept. 25, 1997, at 1B (Mid-

night Gambler—lack of food preparation license).

For a sampling of casino boat insurance disputes, see Florida

Day Cruises, Inc. v. Insurance Co. of N. Am., 2003 WL

22100691 (S.D.N.Y. 2003) (allision); In re Ocean Dev. 1,

LLC, 2012 WL 2050744 (Bankr. S.D. Fla. 2012) (hull damage);

In re SunCruz Casinos LLC, 342 B.R. 370 (Bankr. S.D. Fla.

2006) (set-offs).

Although minor repairs can be done between (or sometimes

even during) cruises, more substantial ones require the ship to

be taken out of service. See, e.g., Wayne T. Price, Casino

Ship Returns to Action at Port Canaveral, Fla. Today (Mel-

bourne), Oct. 22, 2009, at 6C (‘‘After a nearly month-long hia-

tus, gambling begins again today at Port Canaveral when

26 JARVIS

Fourth, casino boats must make suitable

docking arrangements.

Inadditiontohavingto

follow any appli cable ordinances,

doing so

may necessitate the hiring of longshoremen, pilots,

and other personnel not needed at land-based casinos.

Fifth, casino boats always are at the mercy of the

weather.

On some days, rough seas make sailing

impossible.

On other days, conditions discourage

all but the most intrepid players.

Even in good

weather, a fear of becoming seasick keeps some

customers home.

Sixth, in contrast to a land-based casino, the very

nature of a CTN means that players cannot ‘‘come

and go as they please.’’ Instead, they must commit

(footnote 31 continued) SunCruz Casinos sails its [Suncruz

XII]. The gambling ship went into dry-dock on Sept. 28 for im-

provements and upgrades in Jacksonville.’’); Scott Blake,

Casino Ship Out for Repairs, Fla. Today (Melbourne), Nov.

29, 2007, at 1A (Ambassador II—engine overhaul); Mary Shed-

den, Casino Royale Ship Heads to Bahamas for Fixes, Tampa

Trib., Jan. 17, 2007, at 1 (Bus.).

See, e.g., Joe Capozzi, Riviera Casino Ship Moving South,

Palm Beach Post, June 29, 1995, at 1B (‘‘A casino-gambling

cruise ship that has a lease to operate out of the city marina will

instead sail from the Port of Palm Beach for at least its first

three months while the water around the marina is dredged. .

Club Royale had to seek relief from the port after running

aground on the sandy bottom of a channel near the marina Tues-

day night during a test run to see whether the waters around the

marina could accommodate the 224-foot passenger ship.’’).

See, e.g., Sun Cruz Casinos, L.L.C. v. City of Hollywood,

Fla., 844 So. 2d 681 (Fla. Dist. Ct. App. 2003) (city challenge

to restaurant’s decision to allow casino boats to use its dock);

Christopher F. Aguilar, Gambling Ships Hit Choppy Water,

Fla. Times-Union ( Jacksonville), Jan. 29, 2005, at L1 (casino

boats ordered away from dock due to state’s submerged land

lease); Sarah Prohaska, Lady Luck Hopes to Improve Its Own

with Parking, Palm Beach Post, July 1, 2004, at 1B; Gam-

bling Boats Lead to Conflict in Port Richey, St. Petersburg

Times, May 20, 2002, at 2 (Pasco Times) (recalling past dis-

putes between casino boats and the city over customer parking,

permits, and port charges); Beau Halton, City Deals Casino

Ship Warning; No Permits, Officials Say, Fla. Times-Union

( Jacksonville), Jan. 6, 2001, at 1 (Metro) (Suncruz VII —alleged

violation of six city zoning laws); Cathy Vaughn, Lack of

License Anchors Gaming Ship, Daytona News-J., Mar. 19,

1997, at 1A (Fantasea—improper signage and lack of occupa-

tional license).

See, e.g., Pennington-Gray, supra note 3, at 296 (reporting

that in 2002 CTN operators paid $4 million in stevedoring

and line handling charges).

See, e.g., Ardy Friedberg, Rough Seas, Wind Bedevil Boaters:

Gusts, Debris Bring Hazards, Divert 700-Passenger Casino

Ship’s Docking, S. Fla. Sun-Sentinel, Feb. 16, 1998, at 1B

(‘‘Because of high winds, the 137-foot SunCruz Casino gam-

bling ship, SunCruz VI, was unable to dock at its regular pier

at about 5:30 p.m. on Sunday, then hit a dock about a half-

mile south of Dania Beach Boulevard. The ship, reportedly car-

rying about 700 people, [suffered only] minor damage, but the

passengers were forced to disembark by a ladder.’’).

In August 1995, the Palm Beach casino boat Club Royale

sank while trying to outrun Hurricane Erin, resulting in three

deaths. See Woods v. Estate of Woods, 681 So. 2d 903 (Fla.

Dist. Ct. App. 1996). See also Joe Capozzi et al., Owners

Still Dream of ‘Floating Las Vegas,’ Palm Beach Post,

Aug. 14, 1995, at 1A (explaining that the ship was sailing

with a skeleton crew, was not carrying any passengers, Graeme

Woods was the company’s vice president, and the other two fa-

talities were the ship’s captain and cook).

In Dave Barry’s 2002 novel Tricky Business, a Miami gam-

bling ship (Extravaganza of the Seas) refuses to stay in port

even though Tropical Storm Hector is bearing down on South

Florida. Eventually, readers learn why: a planned rendezvous

with a Bahamian drug boat cannot be rescheduled. See further

John Leland, Loose Lips Sink Cruise Ships: Dave Barry’s Sec-

ond Novel Features Murderous Gangsters and a Classic-Rock

Cover Band, N.Y. Times, Oct. 6, 2002, at F21.

Due to seven-foot seas, SunCruz once prevented three blind

women from sailing. According to the company, the waves

‘‘would have made it difficult for the women to move around

the ship safely.’’ In response, the women filed a discrimination

complaint with state officials and told reporters, ‘‘[T]he deci-

sion to board the ship was [ours] to make, not the captain’s.

‘We sat there and listened to (the ship’s attendant) tell other

people that the seas were high but to have a good time,’ said

[Denyece] Roberts, 38. ‘We expected the same type of courte-

sy.’’’ Janel Stephens, Blind Women Not Allowed on Gambling

Boat, St. Petersburg Times, Apr. 9, 2003, at 12 (Neighbor-

hood).

See Andrew Brainard and Chip Gresham, Motion Sickness:

Background, Pathophysiology, Prevalence, Medscape (Mar.

23, 2016), <http://emedicine.medscape.com/article/2060606-

overview> (‘‘Nearly all people experience motion sickness if

given a strong[-]enough motion stimuli. In many typical con-

ditions, such as on cruise ships, the prevalence ranges from 3–

60%, depending on the study.’’).

Because of the small size of most casino boats, as well as

their lack of stabilizers (a standard feature on multi-day cruise

ships), a bout of seasickness is almost inevitable:

Having made the mistake of trying to ‘‘tough it out’’ on my

first gambling ship excursion, I arrived at the SunCruz

Casino with my own personal supply of motion-sickness

pills.

On arrival at the ticket booth, I found a sign advising of

similar medication available on board. Almost as soon as

he started tickling the ivories, [piano player Jim] Nelson

warned everybody to take advantage of the motion-

sickness pills. Then, moments later, the captain greeted

passengers with yet-another pill advisory.

Despite all that, and seas calm enough on which to

water-ski, a healthy number of those on board ended up

in the ranks of the pale-and-puking.

Once again, ship personnel went out of their way to tend

to those who lost at a different type of gamble. One bar-

tender bolted from her post to offer a soft drink and

snack to a one woman whose sweaty forehead belied her

claims of feeling fine.

On the half-hour cruise back into port, a strange sense

of satisfaction crept over me. While I had lost money, I

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 27

to a specific amount of time (the usual CTN lasts 4–

6 hours, with 2–4 hours available for gambling),

even if they lose all of their money early in the

cruise.

They also must be sure to be at the pier

anywhere from 15 to 30 minutes prior to sailing—

a player who is late risks missing the cruise alto-

gether.

Seventh, while land-based casinos never get so

full that they have to turn players away (due to the

fact that patrons always are entering and exiting),

every casino boat has a maximum carrying capacity

that it is not permitted to exceed.

Eighth, while casino boats, like all businesses,

are subject to lawsuits by customers,

employees,

(footnote 38 continued) had maintained my dignity and

my digestion.

Two out of three ain’t bad.

Jon Rabiroff, Trip Can Be Fun for Those Who Can Stomach It:

Temptations Abound for the Unwary Gambler, Daytona

News-J., May 25, 1997, at 11A.

These facts nettle both serious and casual players:

Moe Noonan, 83-year-old Hollywood resident and hard-

core gambler, boards a gaming ship five days a week for

the pleasure of sitting at a blackjack table for a few hours.

Noonan, though, hates taking an hour-long boat trip to

international waters before he’s able to gamble.

‘‘It’s a pain,’’ he barked the other day before sailing on

the St. Tropez in Port Everglades. ‘‘At least at a casino,

after two hours I can go. I can’t drive home from the

boat. I’ve got to stay there.’’

Gambling boats could be big losers if residents in

Miami-Dade and Broward vote March 8 in favor of permit-

ting slot machines at seven racetracks and jai-alai frontons.

Noonan says he’s voting for it. The gambling cruise is a

five-hour or more commitment. At a racetrack or fronton,

he could come and go as he pleases. .

Slots player Audrey Carey of Margate said being able to

play at pari-mutuels would affect the number of trips she

takes on the gaming boats.

‘‘Instead of coming here five times a year, I’d come

maybe twice,’’ Carey said.

Troubled Waters, supra note 10. See also Patrick Danner, Cruis-

ing into Oblivion, Miami Herald, Aug. 12, 2008, at 1C (‘‘‘The

gaming-boat business was always somewhat handicapped,’ [ma-

rina executive Robert] Christoph [Sr.] said. Passengers must

spend four or five hours on a boat, a curse for someone who

has been unlucky. By the same token, Christoph noted, a passen-

ger with a hot hand has to stop playing once the boat returns to

state territorial waters.’’); Joe Bob Briggs, Vegas Guy: La Cruise

Casino, UPI (Oct. 29, 2002), available at <http://www.upi.com/

Vegas-Guy-La-Cruise-Casino/41051035912120/> (quoting La

Cruise Casino General Manager Ken Morriss as saying, ‘‘Of

course, people always ask us: ‘do we really get the same odds

that we would in Las Vegas on this unregulated [Jacksonville

gambling] ship?’ And yes, you do. All the games and percent-

ages are the same. It sometimes FEELS different because the

actual gaming time is only three and a half hours per cruise. The

percentage on slots is generated over a million pulls—but our

machines only work 7 hours a day. So it can be dangerous for us.

We might have to close when losing. And the customer might

have to disembark when losing.’’) (emphasis in original).

The captive nature of CTN has led one wag to update

Chaucer’s The Canterbury Tales. As his book’s forward ex-

plains: ‘‘Cruise to Nowhere Tales is a modern version of The

Canterbury Tales. It consists of a series of tales told by a group

of tourists on a cruise to nowhere while they wait for their

friends and lovers to finish gambling on the deck below. Each

prologue and tale is an adaption of its counterpart in The Can-

terbury Tales, told in the same verse form and with similar

characters and plot elements.’’ Nicholas Gordon, Cruise to

Nowhere Tales vii (2010).

Players miss cruises all the time for all sorts of mundane rea-

sons, such as getting the boat’s departure time wrong, being held

up in traffic on their way to the port, or forgetting to bring proper

identification. However, I once was told the following story by a

gambling ship’s lawyer who had witnessed the event:

As a courtesy, we allow passengers to scatter their lov ed ones’

ashes when the ship is in international waters. One night, a

woman arrived at check-in carrying an urn containing her

husband’s remains. Because she had not made arrangements

in advance, as we require, she was told she could not do the

scattering on that night’s cruise and would have to leave the

urn in her car. Because the ship was about to sail, she asked

if it would wait for her while she went back to her vehicle.

Told that it could not, she hesitated for a moment and then

threw the urn into a nearby trash can so that she could board.

(Names, dates, and other identifying information omitted at the

lawyer’s request.).

See, e.g., Guard Grounds Gambling Boat, Orlando Senti-

nel, July 18, 2004, at B3 (‘‘The Sterling Casino Lines Ambas-

sador II was barred from sailing out of Port Canaveral Friday by

the U.S. Coast Guard, which said it found numerous safety vi-

olations aboard the gambling ship. Coast Guard officers found

the number of passengers exceeded the ship’s limit of 1,800, of-

ficials said. Investigators said they also found other violations

involving safety training requirements, watertight doors and

certification for crew members.’’).

See, e.g., Clay v. Oceans Casino Cruises, Inc., 2008 WL

4571825 (S.D. Fla. 2008) (slip-and-fall injury); Association

for Disabled Americans, Inc. v. Concorde Gaming Corp., 158

F. Supp. 2d 1353 (S.D. Fla. 2001) (wheelchair-bound patrons

complained that the craps tables on the Casino Princesa were

too high for them to reach); Robert M. Jarvis, Casino Boats

and Dram Shop Act Liability,10Gaming L. Rev. 247 (2006).

Because of the ocean’ s constant motion, casino boats are partic-

ularly vulnerable to sham slip-and-fall lawsuits by players looking

to recoup their gambling losses. See Dale K. DuPont, Rolling the

Dice . on Gambling Boats, Miami Herald,Feb.3,1997,at

22BM. See also Robert M. Jarvis, Gambling Debts at Sea,39J.

Mar. L. and Com. 505 (2008) (pointing out that casino boats

do not have the same collection tools as land-based casinos).

See, e.g., Noell v. Suncruz Casinos, 2009 WL 541329 (M.D.

Fla. 2009) (WARN Act class action); Bose v. Oceans Casino

Cruises, Inc., 2006 WL 3507950 (M.D. Fla. 2006) (Suncruz

XII—race and national origin discrimination claim by dis-

charged captain); Miller v. Paradise of Port Richey, Inc., 75 F.

Supp. 2d 1342 (M.D. Fla. 1999) (retaliation claim); In re Sun-

Cruz Casinos, LLC, 377 B.R. 741 (Bankr. S.D. Fla. 2007) (Sun-

cruz VIII—seaman injured in elevator accident).

28 JARVIS

vendors,

and competitors,

they also regularly

find themselves grappling with legal issues that

are both novel and complex.

Lastly, as everyone knows, ‘‘a boat is a hole in the

water that you throw money into’’ and the word

‘‘boat’’ means ‘‘bring out another thousand.’’

Casino boats fully live up to these adages:

A bankruptcy judge cleared the way Wednes-

day for a California investment group to buy

(footnote 43 continued) As maritime employers, CTN have spe-

cial responsibilities to their employees who are seamen. In

2003, for example, a SeaEscape waiter named Sami Barrak

was shot and paralyzed outside a strip club. Although the

club was held liable, the ship was required to pay $1.2 million

for Barrak’s medical care due to an ancient admiralty doctrine

known as ‘‘maintenance and cure.’’ See Mike Clary, Ex-Waiter

Wins $26 Million Settlement—And New Hope, S. Fla. Sun-

Sentinel, Dec. 13, 2007, at 1B.

See, e.g., American V Ships Ltd., LLC v. Norica Eng’g

Servs., 34 F. App’x 151 (5th Cir. 2002) (suit by company that

provided slot machines to casino boat); Tom Stieghorst, Lien

Scuttles Day Cruises; 2 SeaEscape Sailings Canceled, S.

Fla. Sun-Sentinel, Mar. 26, 2003, at 1D (unpaid repair bills).

See, e.g., Carnival Corp. v. SeaEscape Casino Cruises, Inc.,

74 F. Supp. 2d 1261 (S.D. Fla. 1999) (SeaEscape’s ‘‘Ship Full

of Fun!’’ slogan did not infringe Carnival’s ‘‘Fun Ship’’

mark); Aztar Corp. v. NY Entertainment, LLC, 15 F.

Supp. 2d 252 (E.D.N.Y. 1998), aff’d mem., 210 F.3d 354 (2d

Cir. 2000) (Florida/New York gambling ship’s use of the

name ‘‘Tropicana’’ infringed rights of land-based casino).

See, e.g., Canaveral Port Auth. v. M/V Liquid Vegas, IMO

No. 8222941, 2009 WL 3347596 (M.D. Fla. 2009) (CTN—ap-

plicability of maritime arrest procedures to vessel’s slot ma-

chines); In re Las Vegas Casino Lines, LLC, 454 B.R. 223

(Bankr. M.D. Fla. 2011) (CTN—applicability of Florida’s

civil theft statute); In re Titan Cruise Lines, 353 B.R. 919

(Bankr. M.D. Fla. 2006) (CTN—applicability of Florida’s

fraudulent check laws).

For many years, one of the most hotly-debated issues con-

cerned the applicability of Florida’s sales and use taxes to

CTN: ‘‘The Florida Department of Revenue and the cruises to

nowhere industry have met in court several times over the

years. The cruises to nowhere industry argues that it is engaged

in foreign commerce and thus exempt from state sales and use tax

under s. 212.08, Florida Statutes, while the department contends

that cruises to nowhere are engaged in intrastate commerce and

therefore subject to tax.’’ Florida Senate 2003 Report, supra note

4, at 3. In Florida Dep’t of Rev. v. New Sea Escape Cruises,

Ltd., 894 So. 2d 954 (Fla. 2005), the Court ruled the ships

had to pay, but only on transactions occurring in state waters.

See, e.g., Jonathan Waldman, Rust: The Longest War

xiii (2015) (‘‘They say a lot of things about boats. They say a

boat is a hole in the water that you throw money into. They

say boat stands for ‘bring out another thousand.’ They say that

the pleasures of owning and sailing a boat are comparable to

FIG. 1. Locations of Florida’s Cruises-to-Nowhere (as of Jan. 1, 2017).

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 29

the Ocean Jewel of St. Petersburg and refur-

bish the ship to resume offshore gambling.

Attorneys for defunct Titan Cruise Lines

and its largest creditor told bankruptcy Judge

Alexander Paskay that Yamashiro Financial

Services planned to keep the ship in the

Tampa Bay area. .

Owned by a group of Illinois businessmen,

Titan burned through about $90-million dur-

ing its three-year history, said Dennis Shepard,

an outsider brought in to run the company in

the past months.

More than 300 investors from the Chicago

area lost a total of $40-million to $50-million,

he said.

First American, a suburban Chicago com-

munity bank that financed the startup cruise

company, was the biggest loser. The bank is

owed $20-million and will recoup $3-million

to $4-million from the ship sale, said First

American attorney Ron Peterson.

III. SURVIVORS

Florida’s last three casino boats are located, respec-

tively, in Jacksonville,

Port Canaveral (55 miles

east of Orlando), and Port Richey (40 miles north

of Tampa) (see Fig. 1). Reflecting the old real estate

adage, ‘‘location, location, location,’’ these sites

boast two important advantages. First, they are all

densely populated.

Second, each is in a part of

Florida that has few other gambling options.

In North Florida, part of the country’s Bible Belt,

gambling is vigorously opposed on religious grounds.

(footnote 47 continued) standing, fully clothed, in a cold shower

while tearing up twenty-dollar bills. Consequently, they say that

the best day of a sailor’s life, aside from the day he buys a boat, is

the day he sells it.’’).

Steve Huettel, Judge Okays Casino Boat Deal, St. Peters-

burg Times, Jan. 12, 2006, at 1D.

Because of its history, this location also is referred to as

‘‘Mayport.’’ On May 1, 1562, Admiral Jean Ribault of France

discovered a body of water (the present-day St. Johns River)

and dubbed it ‘‘Riviere de Mai’’ (May River). The spot where

he came ashore grew into the village of Mayport. See Kevin

M. McCarthy, St. Johns River Guidebook 129–42 (2d

ed. 2008). McCarthy includes a helpful map to orient readers.

See id. at 131.

If one were to draw 25-mile circles around them, the resulting

population figures would be: Jacksonville—1 million, Port

Canaveral—2.5 million, and Port Richey—1.2 million. See

<https://www.freemaptools.com/find-population.htm>.

In 2014, the Island Breeze operated for three months in Palm

Beach. Its owner later blamed its demise on its unfavorable lo-

cation:

A gambling ship launched last year at the Port of Palm

Beach based its operation on other failed business models,

and it’s difficult for a casino ship to compete when it’s not

far from on[-]shore casinos such as those in Pompano

Beach, according to court records.

Robert Furr, a Boca Raton attorney appointed as trustee in

Island Breeze International’s bankruptcy case, brought the

information to light in a motion to dismiss filed this month.

The company’s principal, Brad Prader, testified that the

operations he used as models for his business had in fact

failed or filed for bankruptcy, court documents state.

Furr asked that the case be dismissed because there is

nothing for the trustee to liquidate. IBI leases the ship,

and its secured creditor, Source-Point LLC, has a lien on

its assets, which mainly consist of gaming equipment

and other items on board.

Furr also questioned whether the operation could have

been viable given its location. Isle Casino Racing at Pom-

pano Park offers gaming such as live poker and slot ma-

chines, as does the Seminole Casino in Coconut Creek.

‘‘I have learned it is very difficult to operate a gambling

boat when there are on shore casinos readily available as

there are in Pompano Beach, Florida, not far from the mar-

ket that might be serviced by that particular boat. In parts

of the country where there are no other casinos, the gam-

bling boat might be a viable business alternative, but not in

this situation. . ’’

Susan Salisbury, Was Gambling Cruise Sunk Before It

Launched?; Trustee: Presence of Onshore Casinos Made Com-

petition Difficult, Palm Beach Post, Feb. 16, 2015, at 1A.

When the owners of the Southern Elegance announced plans to

bring the vessel to North Florida, huge religious protests broke out:

Casino gambling was supposed to make its first legal appear-

ance in Florida’ s Bible Belt We dnesday, but a higher power—

the U.S. Coast Guard—put off the debut for at least a day.

But the Coast Guard’ s last-minute decision to postpone

the inaugural voyage of the Southern Elegance, the casino

cruise ship docked in this coastal Panhandle city, won’t

keep Panama City casino-free.

For that, local preachers and business leaders must appeal

to an ev en higher power. The state and federal governme nts

say there’ s nothing they can do to stop the Southern Elegance

from taking gamblers into international waters in the Gulf of

Mexico to try their luck at 100 slot machines, sev en blackjack

tables and two craps tables. .

‘‘They’’—the fundamentalists who hav e fought the arriv al

of the Southern Elegance for three weeks—have faced off

against those in this coastal city halfway between Tallahassee

and Pensacola who stand by an equally strong belief: the

power of unbridled capitalism.

In a city that boasts more than 130 churches for 35,000

residents, where the daily newspaper is avowedly and rigidly

libertarian, the clash has been ugly.

‘‘This gambling ship is an affront to the will of the people

and to the law,’’ said T ed Haney, president of Citizens for a

Clean Community, the local anti-casino group. ‘‘A lot of us

30 JARVIS

As a result, the Jackson ville casino boat enjoys a vir-

tual monopoly .

In Central Florida, gambling is discouraged to

protect the region’s convention businesses and

theme parks (which include such corporate heavy-

weights as Disney and Universal).

Thus, the Port

Canaveral boat also has no competition.

The Port Richey boat, on the other hand,

is just an hour away from the Seminoles’ sprawl-

ingHardRockTampa(HRT)casino.Butbe-

cause HRT is a luxury property, with prices to

match,

the Port Richey boat has managed to

carve out a niche for itself by catering to locals

looking for a more intimate, and less pricey,

venue.

In South Florida, the population always has been

pro-gambling (indeed, rabidly so).

As a result, nu-

merous casino boats once dotted its shores. Today,

(footnote 52 continued) have a moral objection to bringing

gambling into Bay County .’’

‘‘I lov e all you Baptists and I hope we remain friends, ’’ re-

tired law yer Earl Duncan said at a city debate over the

ship. ‘‘But I want that cruise ship.’’

Marc Fisher , Coast Guard Delays Debut of Panhandle Casino

Ship, Miami Herald, June 12, 1986, at 28A.

See further Roger Bull, Betting on the First Coast: New

Casino Ship at Mayport Will Try to Buck a State Gambling

Trend, Fla. Times-Union ( Jacksonville), June 21, 2014, at D1.

No matter where they set up shop, Florida’s CTN operators

must contend with the state lottery, which began operations in

1987 and has proven to be a fierce competitor. See Florida

Lottery, Measuring Success: 2014–2015 Achievement

Report 17 (2015), available at <http://www.flalottery.com/

exptkt/annualreport14-15.pdf> (‘‘The Florida Lottery finished

fiscal year 2014–15 with an all-time annual sales record of $5.58

billion. This standing would put the Florida Lottery, if it was a

private company, on the Fortune 500 list where it would rank

higher than Neiman Marcus, Levi Strauss, Williams-Sonoma

and Raymond James.’’).

Florida’s CTN operators also must compete with the growing

popularity of Internet gambling. Although presently illegal, the

Florida Legislature at various times has considered legalizing

some types of online betting, such as poker and fantasy sports.

See H.B. 1441 (2010) (Internet Poker Consumer Protection and

Revenue Generation Act); S.B. 832 (2016) (Fantasy Contest

Amusement Act). In addition, Internet cafe

s, which offered

sweepstakes-style betting, flourished in Florida until a 2013

scandal involving Lieutenant Governor Jennifer Carroll caused

them to be banned. See Bill Cotterell, Gov. Scott Signs Bill

Outlawing ‘‘Internet Cafes,’’ Tampa Trib., Apr. 11, 2013, at 4.

Besides not wanting the additional competition, Disney be-

lieves gambling in incompatible with its carefully cultivated

family image. As a result, it is the only major multi-day cruise

operator whose ships do not have casinos on them. See further

Lizette Alvarez and Michael Snyder, In Florida, Gambling

Debate Entangles Disney, N.Y. Times, Oct. 27, 2013, at A16.

Ironically, it gets most of it customers from tourists taking a

break from Orlando’s attractions. See Dave Berman, Gambling

Pays Off for Victory Casino, Fla. Today (Melbourne), Apr.

22, 2014, at A1 (‘‘About 85 percent of the ship’s passengers

come to Port Canaveral from at least 50 miles away’’). See

also Sara K. Clarke, Casino Ship Seeks Inland Customers,

Orlando Sentinel, July 29, 2011, at B5.

See, e.g., Jim Abbott, Gamble, Gander Inside Hard Rock ,

Orlando Sentinel, May 11, 2014, at F3 (‘‘The casino is

part of a 250-room luxury hotel (seminolehardrocktampa.com)

that isn’t for bargain-hunters. My search for available nights in

May and June found rooms priced from $209 to $1,009 a night.

For that money, guests stay in surroundings ‘designed to cater to

rock royalty’ that have received the prestigious Four Diamond

rating from the American Auto Association for seven straight

years. I didn’t stay there. Instead, I walked uncertainly around

the fringe of the Hard Rock Casino. Even non-gamblers can ap-

preciate that it’s an immense space, offering an orgy of color

and noise that one would expect from the world’s sixth-largest

casino.’’).

The boat’s homespun nature was made clear in a recent mag-

azine article:

Everyone wants a bargain. Right? Well, here is one for you

right in Port Richey. Whether you are looking for a serene

day on the quiet waters of the Pithlascotee River; watching

for dolphins or sea turtles in the Gulf; savoring a Reuben, a

quarter-pound Coney Island hot dog, chicken Caesar salad

and more; enjoying the fiery glow of the setting sun; danc-

ing or singing karaoke along with a live DJ—or if you just

love gambling—come to the Tropical Breeze Port Richey

Casino, right next door to Hooters on the west side of U.S.

19 just north of the river.

Tropical Breeze is a family-owned-and-operated busi-

ness. Their company through the years has been named

Pair-A-Dice, Paradise, SunCruz, Port Richey Casinos

and now Tropical Breeze. The business is still owned by

Alex Kolokithas and run with the help of his daughter

Stacy Falcone, her husband Mark, son in-law Bryan Gil-

christ and Assistant CEO Beth Fifer, who have all been

with the company since its beginning 20 years ago. Not

only that, but many of the employees have also been

with the company since the beginning, Fifer said.

Alex, his wife Mollie, and their three children were the

creators and founders of SunCruz Port Richey Casino. .

In 1992, Mollie had an idea of opening a casino day-cruise

named Mr. Lucky that sailed out of Tarpon Springs; it was

the first in the area. . The casino grew rapidly, so in 1995

they opened two others, one in Crystal River and one in

Port Richey. ‘‘Because the industry and economy changed,

we now only operate the one,’’ said Stacy. .

‘‘Our goal,’’ said Stacy, ‘‘is to give our customers a safe,

comfortable gambling experience that is less expensive

and local. We are a community-oriented business, active

members of the West Pasco Chamber of Commerce and

supportive of our local businesses by buying here when-

ever we can.’’

Denise Zahn, Fun’s a Sure Bet, Boomerz Mag., Aug. 2015,

at 5, available at <http://boomerzmagazine.com/wp-content/

uploads/2015/08/Boomerz-Aug15PINweb1.pdf>.

See, e.g. , Robert M. Jarvis, Gambling in Palm Beach County,

Florida,18Gaming L. Rev. and Econ. 702 (2014).

Like others, by ‘‘South Florida’’ I mean ‘‘Southeast Florida’’

(i.e., Fort Lauderdale, Miami, Palm Beach, and, depending on

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 31

however, none do.

This is due in part to the fact

that there are four Indian casinos in South Florida,

including the Seminoles’ massive Hard Rock Holly-

wood (HRH) complex (HRT’s sister),

and in part

to the fact that most of South Florida’s pari-mutuel

facilities have slot machines.

The Jacksonville and Port Canaveral boats are

operated by Tynda Holdings LLC, a Delaware com-

pany that does business under the name Victory

Casino Cruises (VCC).

In Jacksonville, VCC’s

boat is known as the Victory II; built in 1981, it is

196 feet long and has room for 600 passengers.

In Port Canaveral, VCC’s boat is known as the Vic-

tory I ; built in 1972, it is 309 feet long and can ac-

commodate up to 1,400 passengers.

As VCC’s web site explains,

the Victory I does

two sailings every day and charges $13 per cruise.

The Victory II sails twice daily Wednesday through

Sunday and also charges $13 per cruise. Both ships

offer blackjack, craps, poker, roulette, slots, and

sports books; the Victory I also has bingo. Meals

are available for purchase, and anyone can become

a member of the line’s frequent guest program (‘‘Vic-

tory Card’’). On TripAdvisor, the Victory I scores a

(footnote 58 continued) the context, the Keys). In contrast,

‘‘Southwest Florida’’ (consisting of such cities as Bonita

Springs, Fort Myers, and Naples) always has been much more

conservative. Nevertheless, for 18 years the BIG ‘‘M’’ casino

boat sailed out of Fort Myers. It stopped doing so in 2015.

See Casey Logan, Big ‘M’ Says Bye to Fort Myers Beach,

News-Press (Fort Myers) (Oct. 7, 2015), <http://www.ne ws-

press.com/story/money /2015/10/07/ big-m-casino-ship -fort-myers-

beach/73526396/> (reporting that the ship’s owner had decided

to move the vessel to South Carolina).

The most recent casino boat to go bust in South Florida is

the Blue Horizon. See David Raterman, Blue Horizon

Halts Gambling Cruises Out of Palm Beach Port, S. Fla.

Sun-Sentinel, Apr. 8, 2016, at 14 (Showtime) (‘‘Blue Horizon

Casino Cruises has stopped operations out of the Port of Palm

Beach. The gambling ship’s website said, ‘This difficult busi-

ness decision has been made by the owners as it has become in-

evitable [that] the [renewal of the] Seminole Tribe compact will

be enacted. The casino day-cruise industry in the state of Flor-

ida can not (sic ) compete with this land-based expansion of

gaming.’ . . The 160-foot ship had struggled to stay afloat fi-

nancially, putting millions of dollars into renovations and halt-

ing operations a couple of other times in the past year.’’).

In addition to HRH, the Seminoles have a second casino in

Hollywood (known as ‘‘Classic’’) as well as one in Coconut

Creek (which is aimed at the Palm Beach market). See Our

Properties, Seminole Gaming, <http://www.theseminolecasinos

.com/>. In Miami-Dade County, a different tribe (the Micco-

sukees) operates a casino in far western Miami. See Gaming,

Miccosukee Tribe of Indians of Florida, <http://www

.miccosukee.com/gaming/>. Unlike the Seminoles, who are

able to offer Class III games, the Miccosukees, who have

chosen not to seek a compact from the state, are limited to Class

II games. See Nick Sortal, Miccosukees Steer Clear of Politics:

Tribe Still Offers Class II Bingo-Type Slots—No Blackjack, No

Taxes, No Hassle—Bingo Hall Offers Five-Figure Jackpot,

Miami Herald, Mar. 18, 2016, at 25G.

See supra note 13. In June 2016, the Florida Supreme Court

heard oral arguments in a case brought by pari-mutuel facilities

located in other parts of the state. They believe they too are en-

titled to slots so long as they obtain permission from local voters.

See Gretna Racing, LLC v. Department of Bus. and Prof’l Reg.,

178 So. 3d 15 (Fla. Dist. Ct. App.), review granted, 2015 WL

8212827 (Fla. 2015). Even if the Court rejects this argument

(as seems likely), at some point the Florida Legislature probably

will greenlight it. See Jim Saunders and Dara Kim, Slot Machine

Spread Backed, S. Fla. Sun-Sentinel, Dec. 21, 2016, at 3B

(‘‘Amid a tangle of legal issues, [Florida] Senate President Joe

Negron on Tuesday signaled support for allowing slot machines

in . counties where voters have approved expanded gambling.

Voters in Duval and St. Lucie counties last month approved ref-

erendums to allow slot machines at pari-mutuel facilities, join-

ing six other counties [Brevard, Gadsden, Hamilton, Lee,

Palm Beach, and Washington] that had done so earlier.’’).

Of course, any increase in land-based slots likely would be

the final nail in the coffin of Florida’s CTN industry. In its un-

successful effort to defeat Brevard County’s 2012 referendum,

Port Canaveral’s operator told voters as much:

Melbourne Greyhound Park [is] looking to add[] 2,000 slot

machines to [its] existing dog racing, simulcast and poker

operation—if [it] can persuade local voters to say yes to

a referendum on the November ballot that would open

the door to slots and then get a license from the state.

The expansion could make it easier for local gamblers to

get their fix, but also sets up a conflict with the casino

cruise ship at the port as well as Florida anti-gambling or-

ganizations.

Victory Casino’s operators argue land-based slots in

Melbourne will p ut them out of business, endangering

jobs there and reducing revenue for the port. But Mel-

bourne Greyhound Park says its expansion would create

hundreds of new jobs and provide millions of dollars in

new tax revenue for local and state governments.

Wayne T. Price, Slots Could Bring Jobs to Brevard, But Are

They Legal?, Fla. Today (Melbourne), Oct. 21, 2012, at 1C.

This information is taken from paragraph 1 of the complaint

Tynda filed in June 2016 alleging that another company (not in-

volved in the CTN industry) was infringing its trademark. See

Tynda Holdings LLC v. Victory Cruise Mgmt., Inc., Case No.

1:16-cv-22266-JAL (S.D. Fla.), available at <https://ecf.flsd

.uscourts.gov/doc1/051116613198> [hereinafter Tynda Com-

plaint].

Id.at{{ 20–22. For a photograph of the Victory II, see

<http://firstcoastmagazine.com/wp-content/uploads/2014/08/

casino1.jpg>.

Tynda Complaint, supra note 62, at {{ 17–19. For a photo-

graph of the Victory I, see <http://www.shipspotting.com/

gallery/photo.php?lid=2279483>.

See <http://www.victorycasinocruises.com/>. This site re-

directs users to separate ones for Jacksonville (<http://

victoryjax.com/>) and Port Canaveral (<http://victorycasino

cruises.com/index.php>).

32 JARVIS

4.0 out of a possible 5.0 based on 899 reviews.

The

Victory II scores a 3.5 based on 135 reviews.

The Port Richey boat, known as the Tropical

Breeze I, is owned by Tropical Breeze Casino

Cruz, LLC.

Built in 1991, it is 78 feet long,

holds 149 passengers, and operates daily except

Tuesdays.

On sail days, it departs in the morning

and then remains anchored off the coast until the

end of the evening. In-between, players take a ten-

der. Boarding costs $8; food is available for pur-

chase aboard the boat. On TripAdvisor, it scores a

2.5 based on 135 reviews.

Unsurprisingly, each of these vessels has a con-

nection to SunCruz. The Tropical Breeze I was the

Suncruz I; the Victory I was the Suncruz XII (most

people, however, remember her as the Surfside

Princess); and the Victory II operated in South Car-

olina as the Suncruz Aquasino.

IV. CONCLUSION

Florida’s CTN industry, which peaked in 1999,

has been in a long and painful decline for years.

Whether the last three boats (and any others that

may yet come along) have a future remains to be

seen. The odds, however, are not promising.

See Victory Casino Cruises, TripAdvisor, <https://www

.tripadvisor.com/Attraction_Review-g34117-d2229441-Rev ie ws-

Victory_Casino_Cruises-Cape_Canaveral_Brevard_County_

Florida.html>.

See Victory Casino Cruises Jacksonville, TripAdvisor,

<https://www.tripadvisor.com/Attraction_Review-g60805-

d6861661-Reviews-Vi ctory_Casino_Cruises_Jacksonville-

Jacksonville_Florida.html> .

The information in this paragraph comes chiefly from DEP

Registration Program, supra note 17; Zahn, supra note 57;

the company’s web site (<http://www.portricheycasino.com/>);

Florida’s state corporate records (<http://search.sunbiz.org/

Inquiry/CorporationSear ch/ByName>); and a lengthy (9:44

minutes) YouTube video entitled Tropical Breeze Casino Sun

Cruz Port Richey Florida, available at <https://www.youtube

.com/watch?v=BXxzpu6coV4>.

For a photograph of the Tropical Breeze I, see <http://

img2.10bestmedia.com/Images/Photos/190902/p-Tropical-

Breeze-Casino-Boat-1_54_990x660_2014053123 36.jpg>.

See SunCruz Port Richey Casino, TripAdvisor, <https://

www.tripadvisor.com/Attraction_Review-g3457 7-d2538016 -

Reviews-SunCruz_Port_Richey_Casino-Port_Richey_Florida

.html>.

See National Oceanic and Atmospheric Administration

(NOAA) National Marine Fisheries Service, Coast Guard Ves-

sel Documentation, NOAA, available at <http://www.st.nmfs

.noaa.gov/pls/webpls/cgv_pkg.vessel_name_list> (name search

results for each vessel).

FLORIDA’S ‘‘CRUISES TO NOWHERE’’ INDUSTRY 33