Like all other civil cases, it is also necessary in admiralty cases for a decision as to one party, to be certified as final so that it can be appealed when other parties’ claims against each other have not been finally determined.  However, it does not override the right to appeal pursuant to statutory provisions governing appeal of interlocutory orders determining the rights and liabilities of parties.  Therefore, it can be said that a certificate proving a decision to be final is not necessary for appealing interlocutory orders determining the rights and liabilities of parties, whereas it shall be required if an appeal is filed as one of a final order adjudicating fewer than all of the claims of all of the parties.  The Court of Appeals has the authority to correct an appeal of a judgment mistakenly entered on the basis of the certification rule to an interlocutory appeal.

In Gulf Towing Co. v. Steam Tanker, Amoco New York, 648 F.2d 242 (5th Cir. Fla. 1981), appellant ship pilot challenged the decision of the U.S. District Court for the Middle District of Florida, which held that the damage to a tug was caused by appellant’s negligence that was imputed in rem to the ship that appellant piloted.  The trial court held that the pilotage agreement did not constitute a contract due to lack of consideration and, alternatively, because it was void as against public policy.  While deciding the case, the court held that certification was not a prerequisite in admiralty appeals from interlocutory decrees determining the rights and liabilities of the parties.