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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO.:

ILONA ISOM

Plaintiff,

vs.

CARNIVAL CORPORATION, 

Defendant.

___________________________/ 

COMPLAINT AND JURY DEMAND

 COMES NOW the Plaintiff, ILONA ISOM (“Plaintiff” or “Mrs. Isom”), by and through 

undersigned counsel, hereby sues Defendant, CARNIVAL CORPORATION (“CARNIVAL”), a 

Foreign Corporation, and alleges: 

THE PARTIES

1. That at all times material Mrs. Isom was a citizen and resident of the State of 

Florida, USA.

2. Defendant CARNIVAL is a Panama corporation with its principal place of 

business in Miami-Dade, Florida. At all material times, upon information and belief, 

CARNIVAL was the owner, operator or pro hac vice of the subject cruise vessel, and the 

employer of or responsible for all the shipboard personnel, including the vessel’s medical staff, 

navigational officers and employees charged with the duty to maintain shipboard equipment, 

including but not limited to automatic sliding glass doors (hereinafter “automatic doors”). 

JURISDICTION & VENUE

3. This action seeks damages that exceeds Seventy-Five Thousand ($75,000.00) 

Dollars, exclusive of costs, interest and attorney fees, and there is complete diversity between the 

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Parties hereto. Thus, this Court has diversity subject matter jurisdiction pursuant to 28 USC 

§1332.

4. That this Court also has admiralty subject matter initial jurisdiction pursuant to 28 

USC §1332 as the alleged negligent conduct and injury occurred on navigable waters and the 

impact of which had the potential to disrupt maritime commerce.

5. That at all times material the Defendant, CARNIVAL CORPORATION, 

(hereinafter “CARNIVAL”) was the owner, operator, or pro hac vice of the Vessel.

6. This Court has personal jurisdiction over the Defendant and venue is proper as: 

a. CARNIVAL’S principal places of business is located within Miami-Dade 

County, Florida; and/or 

b. CARNIVAL conducts substantial business within the State of Florida, 

including but not limited to operating passenger cruise vessels departing and 

returning to ports located in Miami, and/or Tampa, Cape Canaveral, Ft. 

Lauderdale, and Jacksonville; 

c. CARNIVAL issued a ticket contract requiring this personal injury action be 

filed in this Court thereby subjecting itself to this Court’s personal 

jurisdiction. 

7. That venue is proper in this Court under 28 U.S.C. § 1391 as Defendant has its 

principal place of business in Miami-Dade County, Florida and therefore is deemed to reside 

here and/or the cruise line ticket at issue also requires that suit be brought in this Court.

8. That all conditions precedent for filing and maintain this action have been 

satisfied, waived or do not apply. Plaintiff is no longer in possession of her Cruise Ticket 

Contract, but CARNIVAL does have a copy of it. 

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Isom v. Carnival Corp.

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GENERAL ALLEGATIONS 

9. Plaintiff entered into a contract of carriage with the Defendant for the purpose of a 

cruise aboard the CARNIVAL MARDI GRAS. The cruise embarked from Port Canaveral on 

September 11, 2021. While aboard the Vessel, Plaintiff occupied the status of a cruise ship 

passenger. 

10. That Defendant, as common carrier, is engaged in the business of providing 

vacation cruises to the public aboard various vessels, including the subject Vessel. At all times 

material hereto, Defendant owned, operated, managed, maintained and/or controlled the 

CARNIVAL MARDI GRAS. 

11. That Defendant through online, television, radio and print advertisements

specifically market their cruises as family friendly vacations with extensive offerings and 

activities for people of all ages, abilities, and financial stature. 

12. The incident which is the subject of this action occurred on or about September

17, 2021, aboard the cruise ship CARNIVAL MARDI GRAS (hereinafter referred to as, “The 

Vessel”) while The Vessel was in navigable waters.

13. At the time of the incident, Plaintiff occupied the status of a passenger.

14. The Vessel was owned and/or operated and/or maintained by Defendant. 

15. On the date alleged above, Mrs. Isom was in the Lido Marketplace dining room 

for breakfast. Mrs. Isom sat at one of the tables that moments earlier had been sanitized or wiped 

down by a crewmember. Mrs. Isom saw crewmembers sanitizing or wiping down tables in the 

area moments leading up to Plaintiff suffering her injuries. Upon sitting, Mrs. Isom ran her hand 

across the tabletop, sat down and placed her hands on her lap. 

16. Within minutes of doing so. Mrs. Isom felt a burning sensation in the affected 

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areas mostly on her right thigh. Mrs. Isom immediately sought medical care at the ship’s 

medical center for the burning red, welts that appeared on her thighs. 

17. At the ship’s medical center, CARNIVAL had a trial run paramedic on duty who 

merely prescribed a cortisone cream and did not provide any additional treatment.

18. Noticing that the area was not improving with the prescribed medications, 

Plaintiff sought additional medical care with a dermatologist upon arriving home. The

dermatologist diagnosed Mrs. Isom with chemical burns to her thighs and advised that the 

medications prescribed by the CARNIVAL’s medical staff was the incorrect medication for her 

type of injury.

19. As a result, of CARNIVAL’S negligence Plaintiff had to undergo additional 

medical treatment and now suffers from permanent scarring to her right thigh. 

COUNT I

NEGLIGENCE

Plaintiff readopts and alleges paragraphs 1 through 19 as though fully set forth herein, 

and further alleges as follows: 

20. That at all times material, CARNIVAL owed Plaintiff the duty to exercise 

reasonable care under the circumstances. 

21. Defendant owed Plaintiff the duty of reasonable care under the circumstances to 

maintain a reasonably safe premises and the duty to warn Plaintiff of all dangers it knew or 

should have known. 

22. Defendant was negligent as it breached its duty by: 

a. Failing to maintain the dining tables in a reasonably safe manner for 

passengers;

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b. Failing to warn, or sufficiently warn, passengers of the dangers of the 

cleaning chemicals/agents used on the dining tables;

c. Failing to train, or sufficiently train, its crew on the how to properly clean 

and dry the dining tables with shipboard cleaning chemicals/agents;

d. Failing to ensure crewmembers follow and implement policies and

procedures, both shipboard and per manufacturer’s use and warning 

labels, regarding shipboard cleaning chemicals/agents;

e. Failing to comply with its own standards and/or industry standards 

regarding the proper use of shipboard cleaning chemicals/agents; 

f. Selecting a cleaning agent that did not have sufficient safety features 

thereby allowing the passengers to become injured; 

g. All other negligence acts and omissions to be learned in discovery. 

23. With regard to the alleged unsafe, dangerous or defective condition(s), policy(ies) 

or procedure(s), the Defendant:

a. Knew of the foregoing conditions, policies or procedures in advance of the 

subject incident, but did not correct or warn of such, or

b. The foregoing conditions, policies or procedure existed for a sufficient length 

of time so that Defendant, in the exercise of reasonable care under the 

circumstances, should have known of such, but did not correct or warn of 

them, or

c. Insofar as relates to the foregoing conditions, policies or procedures not 

created by the Defendant, Defendant’s knowledge was or should have been 

acquired through (i) prior similar incident(s) and/or (ii) through its 

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maintenance, inspection and/or observation(s) of the aforesaid conditions, 

policy(ies) or procedure(s) through shipboard personnel present at times 

leading up to and/or at the time of the subject incident or who otherwise were 

charged with such duties and/or (iii) through implementation of policies 

and/or procedures intended to prevent creation of such, but did not correct or 

warn of them, or 

d. Insofar as relates to the foregoing conditions, policies or procedures created 

by the Defendant, by or through a person or entity acting for or on its behalf, 

knowledge or notice on the part of the Defendant is obviated because 

Defendant is indirectly / vicariously liable. 

24. Defendant was also aware of the unreasonably dangerous condition posed by the 

cleaning chemicals/agents in that it directed and/or participated in the selection and purchase of 

said chemicals/agents.

25. As a result of Defendant’s negligence, Plaintiff suffered bodily injury, pain and 

suffering, disability, mental anguish, loss of capacity for the enjoyment of life, medical and 

nursing care and treatment. These losses are either permanent or continuing in nature. 

COUNT II 

VICARIOUS LIABILITY 

Plaintiff readopts and alleges paragraphs 1 through 19 as though fully set forth herein, 

and further alleges as follows: 

26. That at all times material, CARNIVAL owed Plaintiff the duty to exercise 

reasonable care under the circumstances. 

27. Defendant owed Plaintiff the duty of reasonable care under the circumstances to 

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maintain a reasonably safe premises and the duty to warn Plaintiff of all dangers it knew or 

should have known. 

28. Defendant was negligent as it breached its duty by:

a. Failing to clean the dining tables with a non-irritating chemical 

cleaner/agent;

b. Failing to use shipboard cleaning chemicals/agents in prescribed 

concentrations so as to avoid caustic solutions;

c. Failing to properly clean and dry the dining tables with shipboard 

chemical cleaners/agents prior to passenger use;

d. Failing to maintain the dining tables in a reasonably safe manner for 

passengers free of shipboard chemical cleaners/agents;

e. Failing to properly advise passengers of the dangers of the cleaning 

chemicals/agents used on the dining tables;

f. Failing to properly cordon off the area and/or block access to the dining 

tables while still wet with cleaning chemicals/agents;

g. Failing to post signs warning and/or cautioning that the dining tables are 

cleaned with chemicals/agents that can cause burns; 

h. All other negligence acts and omissions to be learned in discovery. 

29. With regard to the alleged unsafe, dangerous or defective condition(s), policy(ies) 

or procedure(s), the Defendant:

a. Knew of the foregoing conditions, policies or procedures in advance of the 

subject incident, but did not correct or warn of such, or

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Isom v. Carnival Corp.

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b. The foregoing conditions, policies or procedure existed for a sufficient length 

of time so that Defendant, in the exercise of reasonable care under the 

circumstances, should have known of such, but did not correct or warn of 

them, or

c. Insofar as relates to the foregoing conditions, policies or procedures not 

created by the Defendant, Defendant’s knowledge was or should have been 

acquired through (i) prior similar incident(s) and/or (ii) through its 

maintenance, inspection and/or observation(s) of the aforesaid conditions, 

policy(ies) or procedure(s) through shipboard personnel present at times 

leading up to and/or at the time of the subject incident or who otherwise were 

charged with such duties and/or (iii) through implementation of policies 

and/or procedures intended to prevent creation of such, but did not correct or 

warn of them, or

d. Insofar as relates to the foregoing conditions, policies or procedures created 

by the Defendant, by or through a person or entity acting for or on its behalf, 

knowledge or notice on the part of the Defendant is obviated because 

Defendant is indirectly / vicariously liable. 

30. Defendant was also aware of the unreasonably dangerous condition posed by the 

cleaning chemicals/agents in that it directed and/or participated in the selection and purchase of 

said chemicals/agents.

31. As a result of Defendant’s negligence, Plaintiff suffered bodily injury, pain and 

suffering, disability, mental anguish, loss of capacity for the enjoyment of life, medical and 

nursing care and treatment. These losses are either permanent or continuing in nature. 

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Isom v. Carnival Corp.

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WHEREFORE, Plaintiff demands judgment against the Defendant, CARNIVAL, for 

compensatory damages, including pre-judgment interest, costs, and all damages allowable by 

law, as well as any further relief as this Court deems just and appropriate.

COUNT III

VICARIOUS LIABILITY FOR NEGLIGENCE OF MEDICAL STAFF

(ACTUAL AGENCY / RESPONDEAT SUPERIOR)

Plaintiff readopts and realleges paragraphs one (1) through sixty-six (19) as though fully 

set forth herein, and further alleges as follows:

32. That at all times material, CARNIVAL owed Plaintiff the duty to exercise

reasonable care under the circumstances. In particular, Plaintiff presented to the Ship’s medical 

center and staff suffering from chemical burns to her legs, and Defendant owed Plaintiff the duty 

to exercise reasonable care to furnish such aid and assistance as ordinarily prudent medical staff 

would render under similar circumstances.

33. That CARNIVAL, by and through its employees and/or actual agents, including 

the Ship’s nurse(s) and physician(s), breached its duty of care owed to Plaintiff in one or more of 

the following ways:

a) Defendant failed to properly assess the gravity of Plaintiff’s medical condition;

b) Defendant prescribed cream that was contraindicated for Plaintiff’s medical 

condition; 

c) Defendant, though its ship’s doctor, failed to appropriately diagnose Plaintiff; 

d) Defendant failed treat Plaintiff in a timely and appropriate manner while she was 

on the Vessel, including but not limited to having insufficient trained medical 

personnel man the medical center without sufficient trained medical supervision;

e) Defendant failed to utilize or adequately utilize available diagnostic equipment

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and/or techniques to assess appropriately Plaintiff’s condition;

f) Defendant failed to properly monitor Plaintiff;

g) Defendant failed to obtain appropriate consultation in a timely manner with landbased specialists available on a 24/7 basis to provide timely and appropriate 

medical care and treatment of Plaintiff;

h) Defendant failed to utilize “Telemedicine” and other resources on the Vessel to 

properly assess Plaintiff’s condition;

i) Defendant deviated from the standard of care for treating patients in Plaintiff’s 

condition.

34. That as a direct and proximate result of the negligence of the Defendant as 

described above, Plaintiff suffered extensive and permanent damage, and will require otherwise 

unnecessary ongoing treatment in the future. That as a further result of the Defendant’s 

negligence, Plaintiff suffered bodily injury and resulting pain and suffering, disability, 

disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of 

hospitalization, medical and nursing care and treatment, and aggravation of a known or unknown 

previously existing condition. The losses are either permanent or continuing in nature and 

Plaintiff will continue to suffer the losses in the future.

35. That the employment relationship and/or actual agency existed as a result of 

written agreements and/or course and conduct, which provided that CARNIVAL had control or 

right of control over the duties and practice of the aforementioned shipboard personnel.

36. That the control or right of control that created the employment relationship 

and/or actual agency included, but was not necessarily limited to the following:

a) That Defendant had the right to hire and fire the Shipboard physician, its nurses and/or 

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Master;

b) That Defendant directly employed and paid a salary to the Shipboard physician, its nurse 

and/or Master;

c) That Defendant had the power to determine the working hours of the Ship’s physician, its

nurse and Master;

d) That Defendant had the right to transfer its physician, other medical personnel and the 

Vessel’s Master to and from any of its Vessels at its discretion;

e) That while under contract to and/or control of Defendant, the physician and nurse were

not permitted to practice medicine either on their own or for any other entity;

f) That the physician and nurse conducted their practice onboard the Vessel and within the

medical center, which was provided by Defendant, including all equipment and 

medicines;

g) That the medical center was created, owned and operated by Defendant;

h) That Defendant represented and held out to immigration authorities and passengers that 

the medical personnel were members of the Ship’s crew;

i) That Defendant selected and provided all of the medicines, equipment, supplies and other 

tools utilized by the Shipboard physician and nurse to treat passengers.

37. That Plaintiff was directly charged for medical services as determined by 

CARNIVAL. 

38. That none of the charges to Plaintiff were received by the Ship’s doctors and/or 

nurses, who instead were paid a salary by CARNIVAL as its employee.

WHEREFORE, Plaintiff demands judgment against the Defendant, CARNIVAL, for 

compensatory damages, including pre-judgment interest, costs, and all damages allowable by 

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law, as well as any further relief as this Court deems just and appropriate. 

COUNT IV: CARNIVAL’S VICARIOUS LIABILITY

FOR NEGLIGENCE OF MEDICAL STAFF

(APPARENT AGENCY)

Plaintiff readopts and realleges the preliminary allegations contained in paragraphs one 

(1) through nineteen (19) as though fully set forth herein, and further alleges as follows: 

40. That at all times material, the Defendant, CARNIVAL, and its Shipboard 

employees, agents and/or apparent agents owed a duty to the Plaintiff to provide prompt and 

appropriate medical care as regards the symptoms with which the Plaintiff presented to the 

Defendant.

41. That the Defendant, CARNIVAL, by and through its employees, including the 

Ship’s nurse and physicians, breached the duty of care which it owed to the Plaintiff and were 

negligent in one or more of the following manners: 

a) Defendant failed to properly assess the gravity of Plaintiff’s medical condition; 

b) Defendant prescribed cream that was contraindicated for Plaintiff’s medical 

condition; 

c) Defendant, though its ship’s doctor, failed to appropriately diagnose Plaintiff; 

d) Defendant failed treat Plaintiff in a timely and appropriate manner while she was 

on the Vessel, including but not limited to having insufficient trained medical 

personnel man the medical center without sufficient trained medical supervision; 

e) Defendant failed to utilize or adequately utilize available diagnostic equipment

and/or techniques to assess appropriately Plaintiff’s condition; 

f) Defendant failed to properly monitor Plaintiff;

g) Defendant failed to obtain appropriate consultation in a timely manner with landCase 1:22-cv-22950-KMW Document 1 Entered on FLSD Docket 09/15/2022 Page 12 of 16
Isom v. Carnival Corp.

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based specialists available on a 24/7 basis to provide timely and appropriate 

medical care and treatment of Plaintiff;

h) Defendant failed to utilize “Telemedicine” and other resources on the Vessel to 

properly assess Plaintiff’s condition;

i) Defendant deviated from the standard of care for treating patients in Plaintiff’s 

condition.

42. That as a direct and proximate result of the negligence of the Defendants as 

described above, the Plaintiff suffered extensive and permanent damage, and will require 

ongoing treatment in the future. That as a further result of the Defendant’s negligence, the 

Plaintiff suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental 

anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical and 

nursing care and treatment, and aggravation of a known or unknown previously existing 

condition. The losses are either permanent or continuing in nature and the Plaintiff will continue 

to suffer the losses in the future.

43. That at all times material, the Defendant, CARNIVAL, held out its medical staff, 

including its doctors and nurses, as being its employees and/or apparent agents who work in the 

Defendant’s “medical centers” on the Vessel. That the Defendant, CARNIVAL, promotes its 

medical staff and represents them as being their employees and/or apparent agents through 

brochures, internet advertising, and on the Vessel. That CARNIVAL held out its staff, including 

Ship’s physician and medical personnel as being direct employees or its apparent agents.

44. That the Defendant, CARNIVAL, promotes the idea that the medical staff who 

work in its “medical centers” are under the control of and acting for and on behalf of 

CARNIVAL as part of a marketing tool to induce passengers such as the Plaintiff to buy cruises 

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on its ships, particularly because the cruise line goes to various foreign ports which may not have 

adequate medical care.

45. That CARNIVAL manifested to the Plaintiff in this case that its medical staff, 

including its Shipboard doctors and nurses were acting as its employees and/or apparent agents 

in various ways, including but not limited to the following: 

(a) the doctor and nurse both worked at what the Defendant describes in its 

advertising as its “medical centers”;

(b) that the “medical centers” are owned and operated by CARNIVAL, which 

pays to stock the “medical centers” with all supplies, various medicines and equipment; 

(c) that the passenger is billed directly by CARNIVAL, whereas the “medical 

staff”, including the doctor and nurse, are paid salaries by CARNIVAL to work in the “medical 

centers”.

46. That the medical staff in this case, including its Shipboard physicians and nurses,

were given uniforms to wear which include name tags, and which have the CARNIVAL name 

and logo. Said uniforms were required by CARNIVAL to be worn by the doctor and nurse.

47. That the doctor is considered to be an Officer on board the Vessel and a member 

of the crew, and was introduced to the passengers as one of the Ship’s Officers.

48. That both the Ship’s doctor and the nurse were held out to the passengers by 

CARNIVAL as being members of the Ship’s crew.

49. That the Defendant put the Ship’s physician and nurse under the command of the 

Ship’s superior officers, including the Master of the Ship.

50. That the cruise line represents to immigration authorities that the physician and 

nurse are members of the Ship’s crew.

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51. That both the Ship’s doctor and nurse eat with the Ship’s crew.

52. That the Ship’s physician and nurse provide services in the Ship’s “medical 

centers” and the Plaintiff was required to go to the Ship’s medical center to be seen for her

condition. 

53. That at the time of Plaintiff’s presentment to the Ship’s medical center, the 

Plaintiff was seen and examined by the Ship’s doctor. 

54. That based on the foregoing, the Plaintiff believed, and was reasonable in her

belief, that the Ship’s doctor was acting as a direct employee and/or apparent agents on behalf of 

the Defendant, and was never given any reason to believe otherwise. 

55. That the Defendant is liable to the Plaintiff for any and all damages as a result of 

negligent medical care by the physician and/or nurse under the theory of apparent agency. 

WHEREFORE, the Plaintiff, ILONA ISOM, demands judgment against the Defendant, 

CARNIVAL, for compensatory damages, including pre-judgment interest, costs, and all damages 

allowable by law, as well as any further relief as this Court deems just and appropriate. 

JURY DEMAND

 Plaintiff hereby demands trial by jury on all issues so triable. 

DATED: September 15, 2022 BRAIS LAW FIRM 

Attorneys for Plaintiff 

Dadeland Office Park 

9300 S. Dadeland Blvd., Suite 101 

Miami, Florida 33156 

Telephone: (305) 416-2901 

Facsimile: (305) 416-2902 

 

By: /s/ Michelle Y. Gurian 

KEITH S. BRAIS

 Florida Bar No. 863319 

kbrais@braislaw.com

MICHELLE Y. GURIAN 

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mgurian@braislaw.com 

Florida Bar No.: 100312 

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