Ever since the U.S. Supreme Court’s decision in Carnival Cruise Lines v. Shute , 499 U.S. 585 (1991) upheld reasonable forum selection clauses in passenger tickets, most cruise lines have required that passenger suits be filed where the carrier maintains its base of operations.

Recent state appellate decisions, such as Leslie v. Carnival , 22 So.3d 567 (Fla. 3d DCA 2009), enforcing more provisions that require such cases to be filed in federal court, have had the effect of funneling these cases to the Southern District of Florida.