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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-cv-22297

RHONDA KELLER,

Plaintiff,

v.

ROYAL CARIBBEAN CRUISES, LTD.,

Defendant.

________________________________/

COMPLAINT FOR DAMAGES 

AND DEMAND FOR TRIAL BY JURY

Plaintiff, RHONDA KELLER (hereinafter “KELLER”), through undersigned counsel, sues 

Defendant, ROYAL CARIBBEAN CRUISES, LTD., (hereinafter “RCCL”), and demands trial by 

jury, stating as follows:

PARTIES AND JURISDICTION

1. KELLER seeks damages in excess of $75,000.00, exclusive of interest, costs, and

attorneys’ fees.

2. This Court has admiralty and maritime jurisdiction pursuant to 28 U.S.C. § 1333.

3. This Court has diversity jurisdiction pursuant to 28 U.S.C. § 1332, as the matter in

controversy exceeds the sum or value of $75,000.00, exclusive of interest and costs, and is between 

citizens of different states and/or citizens of a state and citizens or subjects of a foreign state. 

4. Suit is filed in federal court because of the federal forum selection clause in the

passenger contract ticket issued by RCCL.

5. KELLER is sui juris and is a resident and citizen of the state of Pennsylvania.

6. RCCL is a citizen of the state of Florida and the nation of Liberia.

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7. RCCL is a foreign corporation who is authorized to conduct and who does conduct 

business in the state of Florida, who at all times material hereto was and is doing business in 

Miami-Dade County, Florida, and who maintains its corporate headquarters and principal place of 

business in Miami-Dade County, Florida.

8. RCCL, at all times material hereto, personally and/or through an agent, in MiamiDade County, Florida, in the Southern District of Florida:

a. Operated, conducted, engaged in, or carried on a business venture; and/or

b. Had an office or agency; and/or

c. Engaged in substantial activity; and/or

d. Committed one or more of the acts stated in Florida Statutes, §§ 48.081, 

48.181 or 48.193.

9. All conditions precedent for filing and maintaining this action have been fulfilled, have 

been waived, or do not apply.

DEFINITIONS AND FACTUAL ALLEGATIONS

10. Hereinafter, the phrase, the “subject area,” shall include, but not be limited to, the subject 

deck surface KELLER fell on, and all material and effects pertaining thereto, including the subject 

flooring and/or other parts thereof, slip resistant materials that were or should have been applied, the 

floor and surface’s design and/or visual condition, and/or any other applied, adhesive, and/or other 

material, and the surrounding area.

11. At all times material hereto, RCCL owned, leased, chartered, operated, maintained, 

managed, and/or controlled the subject cruise ship, the Allure of the Seas.

12. KELLER’S incident occurred on or about June 26, 2022, while she was a fare paying 

passenger on RCCL’S vessel, the Allure of the Seas.

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13. At all times material hereto, RCCL owned, leased, chartered, operated, maintained, 

managed, and/or controlled the subject area involved in KELLER’S incident.

14. On or about June 26, 2022, KELLER was walking on Deck 16 in a normal and proper 

manner. However, unbeknownst to her, there was liquid on the deck, and she slipped and fell when 

she walked over this liquid.

15. As a result, KELLER suffered severe injuries, including, but not limited to, injuries 

to her wrists, which may require surgery(ies).

16. When KELLER was taken to the ship’s medical center, the ship’s doctor unreasonably 

pulled on KELLER’S arm, causing her great pain. Moreover, the ship’s doctor tightened 

KELLER’S wrappings to an unreasonable degree, causing her further injuries.

17. At all relevant times, the dangerous and/or risk creating conditions include, but are 

not limited to the following:

a. The surface KELLER slipped on was contaminated with a foreign liquid 

substance.

b. The surface KELLER slipped on was unreasonably slippery.

c. The surface KELLER slipped on lacked adequate slip resistance, slip resistant 

treatment, and/or any such slip resistant treatment was unreasonably poorly 

maintained and worn down and/or otherwise unreasonably dangerous such 

that they were not reasonably reducing the slipperiness of the subject area.

d. The visual condition of the surface was such that it was difficult for a 

reasonable person to discern that it was slippery prior to KELLER’S fall.

e. There was inadequate drainage for the subject area at the time of KELLER’S 

incident.

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f. Carnival provided no reasonable towels, devices, or other means to dry 

passengers or the floor in the subject area.

g. ROYAL CARIBBEAN CRUISES, LTD. did not have sufficient supervision 

of the subject area.

h. Other dangerous conditions that will be revealed through discovery.

18. Each of these dangerous conditions alone was sufficient to cause KELLER’S incident 

and injuries, and KELLER is alleging that RCCL was negligent as to each of these conditions

separately and not cumulatively. 

19. RCCL either knew or should have known of these risk-creating and/or dangerous 

conditions, due to reasons that include, but are not limited to, the following: 

a. After her incident, a passenger came to KELLER while she was laying on the ground 

and told her that the floor had been wet for a while (at least 10 minutes) prior to her 

fall.

b. Furthermore, KELLER observed RCCL’S crewmembers in the subject area at the 

time of the incident, and one of them, who appeared to be a maintenance person, came 

up to her after her fall. These crewmembers were in the immediate vicinity, such that 

KELLER reasonably infers that these crew members regularly used, observed, and 

tended to the subject area, and therefore were or should have been aware of the 

dangerous and/or risk-creating conditions thereof, and warned of and/or removed 

these conditions.

c. Both prior to KELLER’S incident and after, Defendant installed and/or refitted similar 

surfaces on the Allure of the Seas and other ships in Defendant’s fleet with surfaces 

that were less slippery and that had visual cues that made them more visible.

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d. RCCL participated in the installation and/or design of the subject area, or 

alternatively, RCCL accepted the area with its design defects present after having been 

given an opportunity to inspect the ship and materials on it, such that RCCL should 

have known of the design defects of the subject area before providing them for public

use. These design defects include, but are not limited to, the structural dangers 

outlined in paragraph 17(b-f, h) of this Complaint.

e. There are relevant safety standards/recommendations/other guidelines regarding the 

safety of the subject area, including, but not limited to, prohibitions and/or 

recommendations against the deficiencies discussed in paragraph 17 of this 

Complaint, and RCCL should have known of these standards/recommendations/other

guidelines because whether such standards/recommendations/other guidelines are 

legally required for RCCL to comply with or not, a fact-finder is entitled to determine, 

if it so choses, that these standards/recommendations/other guidelines show what a 

reasonable Defendant should have done.

f. RCCL also knew or should have known of these dangerous conditions through 

inspecting the subject area involved in KELLER’S incident, and if it did not know of 

these dangerous conditions, this was because RCCL failed to adequately inspect the 

subject area prior to her incident.

g. Additional individuals suffered prior incidents, injured both due to the same and/or

substantially similar slippery surfaces on ROYAL CARIBBEAN’S ships, including,

but not limited to, slip and fall incidents on liquid substances. See Apontev v. Royal 

Caribbean Cruise Lines Ltd., 739 F. App'x 531, 537 (11th Cir. 2018) (passenger 

slipped and fell aboard another one of ROYAL CARIBBEAN’S ships in a puddle of 

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liquid); see also Hawkins v. Royal Caribbean Cruise Lines Ltd., Case 1:22-cv-22052-

RNS (passenger slipped and fell aboard another one of ROYAL CARIBBEAN’S ships 

in a puddle of liquid)

h. Moreover, RCCL knew or should have known of these dangerous conditions for other 

reasons that will be revealed through discovery.

20. At all times relevant, the subject area was unreasonably dangerous, risk-creating, 

defective, improperly designed, improperly installed, and/or otherwiseunsafe.

21. The subject area and the vicinity lacked adequate safety features to prevent or minimize 

KELLER’S fall and/or impact.

22. These hazardous conditions were known, or should have been known, to RCCL in the 

exercise of reasonable care.

23. These hazardous conditions existed for a period of time before the incident.

24. These conditions were neither open nor obvious to KELLER.

25. At all times relevant, RCCL failed to adequately inspect the subject area and the vicinity

for dangers, and RCCL failed to adequately warn KELLER of the dangers.

26. At all times relevant, RCCL had the ability to cure the deficiencies and to eliminate the

hazards, but failed to do so.

27. At all times relevant, RCCL failed to maintain the subject area and the vicinity in a 

reasonably safe condition.

28. At all times relevant, RCCL participated in the design and/or approved the design of

the subject area and the vicinity involved in KELLER’S incident.

29. At all times relevant, RCCL participated in the installation and/or approved the 

installation of the subject area and the vicinity involved in KELLER’S incident.

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30. The crewmembers of the Allure of the Seas were in regular full-time employment of 

RCCL and/or the ship, as salaried crewmembers, subject to the ship’s discipline and master’s 

orders.

31. RCCL had the right to hire and fire their employees and/or agents.

32. RCCL is directly responsible and liable for their actions and the actions of its

employees and/or agents.

33. The crewmembers, including the medical staff, were employees and/or actual agents 

and/or apparent agents of RCCL, and acted within the course and scope of their employment and/or 

agency agreement and/or relationship.

34. The crewmembers were represented to KELLER and the ship’s passengers as

employees of RCCL through signs, documents, and/or uniforms. The crewmembers were also paid 

a salary and/or hourly wage by RCCL. RCCL knew that the crewmembers represented themselves 

to be employees of RCCL and allowed them to represent themselves as such. KELLER

detrimentally relied on these representations as she would not have proceeded on the subject cruise 

had she believed the crewmembers were not employees of RCCL.

COUNT I

NEGLIGENT FAILURE TO INSPECT

35. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34 as if set forthherein.

36. RCCL owed a duty to exercise reasonable care under the circumstances for the safety 

of its passengers.

37. This duty includes, but is not limited to, the duty to provide its passengers reasonable 

care by adequately inspecting the subject area and the vicinity to make sure the subject area and 

the vicinity were reasonably safe for the use and enjoyment of its passengers.

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38. At all times material, RCCL, through its vessel, crew, agents, employees, staff and/or 

representatives, who were acting in the course and scope of their employment and/or agency with 

RCCL breached the duty of reasonable care owed to KELLER and were negligent by failing to 

adequately inspect the subject area and the vicinity to make sure the subject area and the vicinity 

were reasonably safe, such that the unreasonably risk creating and/or dangerous conditions 

discussed paragraph 17 of the instant Complaint were present at the time of KELLER’S incident.

39. RCCL either knew or should have known of these risk-creating and/or dangerous 

conditions, due to reasons that include, but are not limited to, the reasons discussed in paragraph 

19 of the instant Complaint.

40. These risk-creating and/or dangerous conditions were caused by RCCL’S failure to 

adequately inspect the subject area and the vicinity to make sure the subject area and the vicinity 

were reasonably safe.

41. Furthermore, the subject area and the vicinity were also on a cruise ship in the open 

sea subject to numerous maritime conditions such as the ship’s movement, additional wear-andtear due to maritime conditions not necessarily present on land, waves, and other conditions unique 

to maritime travel, and as such were “clearly linked to nautical adventure.”

42. RCCL’S negligence proximately caused KELLER great bodily harm in that, but for 

RCCL’S negligence, KELLER’S injuries would not have occurred.

43. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

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44. The losses are permanent and/or continuing in nature.

45. KELLER suffered these losses in the past and will continue to suffer such loses in the 

future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT II

NEGLIGENT FAILURE TO MAINTAIN

46. KELLER hereby adopts and re-alleges each and every allegation in paragraphs

through 34, as if set forth herein.

47. RCCL owed a duty to exercise reasonable care under the circumstances for the safety 

of its passengers.

48. This duty includes, but is not limited to, the duty to provide its passengers reasonable

care by adequately maintaining the subject area and the vicinity.

49. At all times material, RCCL, through its vessel, crew, agents, employees, staff and/or 

representatives, who were acting in the course and scope of their employment and/or agency with 

RCCL, breached the duty of reasonable care owed to KELLER and were negligent by failing to 

adequately maintain the subject area and the vicinity, such that the unreasonably risk creating 

and/or dangerous conditions discussed paragraph 17 of the instant Complaint were present at the 

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time of KELLER’S incident.

50. RCCL either knew or should have known of these risk-creating and/or dangerous

conditions, due to reasons that include, but are not limited to, the reasons discussed in paragraph 

19 of the instant complaint.

51. Moreover, these risk-creating and/or dangerous conditions were caused by RCCL’S

failure to adequately maintain the subject area and the vicinity.

52. Furthermore, the subject area and the vicinity were also on a cruise ship in the open 

sea subject to numerous maritime conditions such as the ship’s movement, additional wear-andtear due to maritime conditions not necessarily present on land, waves, and other conditions unique 

to maritime travel, and as such were “clearly linked to nautical adventure.”

53. RCCL’S negligence proximately caused KELLER great bodily harm in that, but for 

RCCL’S negligence, her injuries would not have occurred.

54. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

55. The losses are permanent and/or continuing in nature.

56. KELLER has suffered these losses in the past and will continue to suffer such losses

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

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pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT III

NEGLIGENT FAILURE TO REMEDY

57. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34 as if set forth herein.

58. RCCL owed a duty to exercise reasonable care under the circumstances for the safety 

of its passengers.

59. This duty includes, but is not limited to, the duty to provide its passengers reasonable 

care by adequately remedying the subject area and the vicinity.

60. At all times material, RCCL, through its vessel, crew, agents, employees, staff and/or 

representatives, who were acting in the course and scope of their employment and/or agency with 

RCCL, breached the duty of reasonable care owed to KELLER and were negligent by failing to 

adequately remedy the subject area and the vicinity, such that the unreasonably risk creating and/or 

dangerous conditions discussed in paragraph 17 of the instant Complaint were present at the time 

of KELLER’S incident.

61. RCCL either knew or should have known of these risk-creating and/or dangerous 

conditions, due to reasons that include, but are not limited to, the reasons discussed in paragraph 

19 of the instant Complaint.

62. Moreover, these risk-creating and/or dangerous conditions were caused RCCL’S 

failure to adequately remedy the subject area.

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63. Furthermore, the subject area and the vicinity were also on a cruise ship in the open 

sea subject to numerous maritime conditions such as the ship’s movement, additional wear-andtear due to maritime conditions not necessarily present on land, waves, and other conditions unique 

to maritime travel, and as such were “clearly linked to nautical adventure.”

64. RCCL’S negligence proximately caused KELLER great bodily harm in that, but for 

RCCL’S negligence, her injuries would not have occurred.

65. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

66. The losses are permanent and/or continuing in nature.

67. KELLER has suffered these losses in the past and will continue to suffer such losses 

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

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COUNT IV

NEGLIGENT FAILURE TO WARN OF DANGEROUS CONDITION

68. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34 as if set forth herein.

69. At all times relevant, RCCL owed a duty to exercise reasonable care under the 

circumstances for the safety of its passengers, including KELLER.

70. Such duty includes, but is not limited to, the duty that RCCL owes to warn passengers 

of any dangers that it knew or should have known were not open and obvious to KELLER.

71. Such duty also includes, but is not limited to, the duty to warn passengers of hazards,

which passengers may reasonably be expected to encounter.

72. At all times material, RCCL, through its vessel, crew, agents, employees, staff and/or 

representatives, who were acting in the course and scope of their employment and/or agency with

RCCL, breached the duty of reasonable care owed to KELLER and was negligent by failing to 

warn KELLER of the dangerous conditions discussed in paragraph 17 of the instant Complaint.

73. Furthermore, RCCL knew or should have known of these dangerous conditions for 

the reasons discussed in paragraph 19 of this Complaint.

74. These dangerous conditions were also created by RCCL.

75. RCCL failed to adequately ensure there were no dangerous conditions that passengers 

needed to be warned of, and/or RCCL failed to warn KELLER despite knowing of the dangers.

76. These dangerous conditions existed for a period of time before the incident. 

77. These conditions were neither open nor obvious to KELLER. 

78. RCCL’S breach was the cause in-fact of KELLER’S great bodily harm in that, but for 

RCCL’S breach her injuries would not have occurred.

79. Furthermore, the subject area and the vicinity were also on a cruise ship in the open 

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sea subject to numerous maritime conditions such as the ship’s movement, additional wear-andtear due to maritime conditions not necessarily present on land, waves, and other conditions unique 

to maritime travel, and as such were “clearly linked to nautical adventure.”

80. RCCL’S breach proximately caused KELLER great bodily harm in that the incident 

that occurred was a foreseeable result of RCCL’S breach.

81. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

82. The losses are permanent and/or continuing in nature.

83. KELLER has suffered these losses in the past and will continue to suffer such loses 

in the future.

 WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

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COUNT V

NEGLIGENT DESIGN, INSTALLATION, AND/OR APPROVAL OF THE SUBJECT 

AREA AND THE VICINITY

84. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein.

85. At all times material hereto, RCCL owed a duty to its passengers, and in particular a 

duty to KELLER, not to permit dangerous conditions to be in places where they could harm 

passengers, such as those discussed in paragraph 17(b-f, h) in the instant Complaint, as well as to 

design and install reasonable safeguards.

86. At all times material hereto, RCCL participated in the design process of the subject 

vessel by generating design specifications for the shipbuilder to follow, and to put the vessel on 

which KELLER was injured into the channels of trade, and/or RCCL approved of the subject 

vessel’s design, including the design of the subject area and the vicinity.

87. At all times material hereto, RCCL manufactured, designed, installed, and/or 

approved of the Allure of the Seas, including providing specifications to the shipbuilder in the 

original build process, and/or during its refurbishments, and as such owed a duty to its passengers, 

and in particular a duty to KELLER, to design, install and/or approve of the subject area and the 

vicinity without any defects.

88. At all times material hereto, RCCL through its agents and/or employees who were 

acting in the course and scope of their employment and/or agency with RCCL, designed, installed, 

and/or approved of the subject area and the vicinity involved in KELLER’S incident, which was 

also in violation of the applicable industry standards/recommendations and/or other guidelines.

89. RCCL provides design elements of the vessels to the ship builder and/or approves of 

design elements which include the subject area and the vicinity.

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90. RCCL maintains the contractual right to participate, review, modify, and/or reject the 

design plans and drawings of the vessels, including the Allure of the Seas, during the new build 

process.

91. RCCL has the right to enter the ship and inspect it during construction to ensure that 

it is being constructed in accordance with the design specifications and has a right to insist on 

changes when safety concerns are identified.

92. RCCL has the right to inspect and reject design elements before taking possession of 

the ship.

93. However, RCCL permitted the dangerous conditions discussed in paragraph 17(b-f, 

h) of the instant complaint to be present in the subject area and the vicinity without correcting these 

design deficiencies and did not design and install reasonable safeguards.

94. The design flaws that made the subject area and the vicinity involved in KELLER’S

incident unreasonably dangerous were the direct and proximate cause of KELLER’S injuries.

95. RCCL is liable for the design flaws of the vessel, including of the subject area and 

the vicinity involved in KELLER’S incident, which it knew or should have known of.

96. RCCL failed to correct and/or remedy the defective conditions, despite the fact that 

RCCL knew or should have known of the danger(s).

97. RCCL’S breach was the cause in-fact of KELLER’S great bodily harm in that, but for 

RCCL’S breach her injuries would not have occurred.

98. Furthermore, the subject area and the vicinity were also on a cruise ship in the open 

sea subject to numerous maritime conditions such as the ship’s movement, additional wear-andtear due to maritime conditions not necessarily present on land, waves, and other conditions unique 

to maritime travel, and as such were “clearly linked to nautical adventure.”

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99. RCCL’S breach proximately caused KELLER great bodily harm in that the incident 

that occurred was a foreseeable result of RCCL’S breach.

100. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

101. The losses are permanent and/or continuing in nature.

102. KELLER has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT VI

NEGLIGENCE FOR THE ACTS OF RCCL’S CREW, STAFF, EMPLOYEES, AND/OR 

AGENTS, BASED ON VICARIOUS LIABILITY

103. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1

through 34, as if set forth herein.

104. RCCL owed a duty to exercise reasonable care under the circumstances for the safety 

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of its passengers.

105. The crewmembers who were working in and/or who were and/or should have been 

responsible for inspecting, maintaining, cleaning, and/or securing the subject area, including 

specifically the crewmembers who were in the subject area at the time of KELLER’S incident, were 

agents of RCCL for the following reasons:

a. They were the staff and/or employees of RCCL, or were RCCL’S agents, apparent 

agents, and/or servants; and/or 

b. These staff, employees, and/or agents were subject to the right of control by RCCL; 

and/or

c. These staff, employees, and/or agents were acting within the scope of their 

employment or agency; and/or

d. RCCL acknowledged that these staff, employees, and/or agents would act on

RCCL’S behalf, and they accepted the undertaking.

106. RCCL is vicariously liable for the acts of its staff, employees, and/or agents, as 

discussed in paragraph 17(g) of the instant complaint.

107. RCCL’S breach was the cause in-fact of KELLER’S great bodily harm in that, but for 

RCCL’S breach her injuries would not have occurred.

108. Furthermore, the subject area and the vicinity were also on a cruise ship in the open 

sea subject to numerous maritime conditions such as the ship’s movement, additional wear-andtear due to maritime conditions not necessarily present on land, waves, and other conditions unique 

to maritime travel, and as such were “clearly linked to nautical adventure.”

109. This negligence proximately caused KELLER great bodily harm in that, but for this 

negligence, KELLER’S injuries would not have occurred.

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110. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

111. The losses are permanent and/or continuing in nature.

112. KELLER has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT VII

VICARIOUS LIABILITY AGAINST RCCL FOR THE NEGLIGENCE OF THE SHIP’S 

MEDICAL STAFF

113. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein.

114. RCCL, through the ship’s medical staff (including its physicians and nurses), and the 

ship’s crew, owed a duty to exercise reasonable care under the circumstances for the safety of its 

passengers.

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115. Such duties include, but are not limited to, providing such medical care and assistance 

as would an ordinarily prudent person under the circumstances.

116. At all times material, the ship’s medical staff (including its physicians and nurses), 

and the ship’s crew, were full-time employees and agents of RCCL, subject to its direction and 

control, who were engaged in the activity of discharging RCCL’S obligation to make such medical 

aid and assistance available to its passengers as would an ordinarily prudent person under the 

circumstances.

117. RCCL is estopped to deny that the ship’s medical staff (including its physicians and 

nurses), and the ship’s crew, were its agents and/or employees and/or servants.

118. RCCL directly paid the ship’s medical personnel and regular crew a salary (i.e., 

payment by time) for their work in the ship’s hospital and in treating passengers.

119. RCCL created, owned, directly provided, and operated, the medical center to be used 

by the ship’s medical personnel and passengers.

120. RCCL pays to stock the medical center with all supplies, medical machinery, various 

medicines, and equipment to be used therein, regularly stocking and restocking same.

121. RCCL collected all medical revenues directly from passengers and generated a profit 

on the sale of medical services, supplies, and equipment made by the ship’s medical personnel to 

the passengers of the vessel.

122. RCCL’S marketing materials described the infirmary in proprietary language.

123. The ship’s medical personnel were members of the ship’s crew; they were subject to 

the ship’s discipline; they were required to wear the ship’s uniforms; they (and, in particular, the 

ship’s physicians) were members of the ship’s officer’s compliment, and at all times they were 

subject to termination, or other discipline, by RCCL.

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124. RCCL provided the ship’s medical personnel certain forms of liability insurance 

and/or indemnification rights.

125. At all times material hereto, RCCL, through the ship’s medical staff (including its 

physicians and nurses), and the ship’s crew, was careless, negligent, and breached its duties as 

follows: 

a. Failing to promptly provide KELLER with proper medical and/or first aid

care and attention;

b. Failing to timely and properly diagnose and/or assess KELLER’S condition;

c. Failing to timely and properly attend to KELLER, to her injuries, and to her

pain;

d. Failing to provide reasonable medical and/or first aid care;

e. Failing to timely and properly treat and care for KELLER;

f. Failing to timely and properly examine KELLER’S injuries;

g. Failing to take proper measures to secure proper treatment for KELLER, 

including unreasonably delaying taking measures to secure such proper 

treatment;

h. Failing to properly bring and/or arrange for KELLER to be brought to an 

emergency room within a reasonable amount of time; and/or

i. Failing to give KELLER proper discharge instructions; and/or

j. Harming KELLER by improperly twisting her arm; and/or

k. Unreasonably tightening KELLER’S wrappings for her injuries to an 

unreasonably degree of tightness; and/or

l. Failing to give KELLER adequate pain medicine.

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126. Pain is a frequently experienced, yet oftentimes overlooked factor in wound care and 

wound healing. It is undeniable that pain affects wound care practice, and unresolved pain 

negatively impacts both wound healing and a patient's quality of life.

127. Under the doctrine of Respondeat Superior, employers are vicariously liable for the 

negligent acts or omissions by their employees and/or other agents within the course of their 

employment and/or agency.

128. RCCL is therefore vicariously liable for all injuries and damages sustained by 

KELLER as a result of the negligence of the ship’s medical staff (including its physicians and 

nurses), and the ship’s crew.

129. At all times material hereto, the aforementioned acts and/or omissions on the part of

RCCL’S ship’s medical staff (including its physicians and nurses), and the ship’s crew, fell below 

the standard of care.

130. The negligence of RCCL’S ship’s medical staff (including its physicians and nurses), 

and the ship’s crew, proximately caused KELLER great bodily harm in that, but for RCCL

negligence, KELLER’S injuries would not have occurred and/or said injuries would have been 

substantially lessened.

131. RCCL, through its employees and agents, to wit, the ship’s medical staff, knew or 

should have known that the medical procedures they employed violated and/or did not meet 

reasonable standards of medical care.

132. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

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KELLER’S vacation, cruise, and transportation costs.

133. The losses are permanent and/or continuing in nature.

134. KELLER has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT VIII

APPARENT AGENCY

FOR THE ACTS OF THE SHIP’S MEDICAL STAFF

135. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein.

136. At all times material hereto, the ship’s medical staff represented to KELLER and to 

the ship’s passengers as employees and/or agents and/or servants of RCCL, in that:

a. The medical staff wore a ship’s uniform;

b. The medical staff ate with the ship’s crew;

c. The medical staff was under the commands of the ship’s officers;

d. The medical staff worked in the ship’s medical department;

e. The medical staff was paid a salary by RCCL;

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f. The medical staff worked aboard the vessel;

g. The medical staff spoke to KELLER as though they had authority to do so by RCCL.

137. In addition, RCCL further represented to KELLER that the vessel’s medical staff 

were agents and/or employees of RCCL through its marketing materials and through other official 

statements that described the infirmary in proprietary language, including language such as the

“RCCL Allure of the Seas’ Medical Center/our infirmary/our medical center,” and through 

encouraging KELLER to make use of “its” infirmary/medical center if KELLER was in need of 

medical attention.

138. Furthermore, at no time did RCCL represent to KELLER in particular, or the ship’s 

passengers in general, in a meaningful way that the vessel’s medical staff were not agents or 

employees of RCCL.

139. At all material times, KELLER reasonably relied on the representations to KELLER’S

detriment that the medical staff were employees, and/or agents, and/or servants of RCCL.

140. It was reasonable to believe that the medical staff were RCCL’S agents because they 

wore a ship’s uniform. In addition, at all times material, the medical staff spoke and acted as though 

they were authorized to do so by RCCL.

141. This reasonable reliance was detrimental because it delayed KELLER from receiving 

proper medical treatment and/or KELLER would not have gone on the subject cruise with RCCL

had KELLER known that the medical staff on the ship were not RCCL’S agents.

142. RCCL is estopped to deny that the medical staff were its apparent agents, and/or 

apparent employees, and/or apparent servants.

143. RCCL had a duty to provide KELLER with reasonable care under the circumstances 

and through the acts of its apparent agents breached its duty to provide KELLER with reasonable 

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care under the circumstances.

144. KELLER’S injuries were aggravated due to the fault and/or negligence of RCCL

through the acts of its apparent agents as follows:

a. Failing to promptly provide KELLER with proper medical and/or first aid

care and attention;

b. Failing to timely and properly diagnose and/or assess KELLER’S condition;

c. Failing to timely and properly attend to KELLER, to her injuries, and to her

pain;

d. Failing to provide reasonable medical and/or first aid care;

e. Failing to timely and properly treat and care for KELLER;

f. Failing to timely and properly examine KELLER’S injuries;

g. Failing to take proper measures to secure proper treatment for KELLER, 

including unreasonably delaying taking measures to secure such proper 

treatment;

h. Failing to properly bring and/or arrange for KELLER to be brought to an 

emergency room within a reasonable amount of time; and/or

i. Failing to give KELLER proper discharge instructions; and/or

j. Harming KELLER by improperly twisting her arm; and/or

k. Unreasonably tightening KELLER’S wrappings for her injuries to an 

unreasonably degree of tightness; and/or

l. Failing to give KELLER adequate pain medicine.

145. Pain is a frequently experienced, yet oftentimes overlooked factor in wound care and 

wound healing. It is undeniable that pain affects wound care practice, and unresolved pain 

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negatively impacts both wound healing and a patient's quality of life.

146. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

147. The losses are either permanent or continuing in nature.

148. KELLER has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

COUNT IX

ASSUMPTION OF DUTY FOR THE

NEGLIGENCE OF THE SHIP’S MEDICAL STAFF

149. KELLER hereby adopts and re-alleges each and every allegation in paragraphs 1 

through 34, as if set forth herein.

150. RCCL owed KELLER the duty to exercise reasonable care under the circumstances 

for the safety of its passengers.

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151. Such duties include, but are not limited to, providing such medical care and assistance 

as would an ordinarily prudent person under the circumstances.

152. RCCL elected to discharge this duty by having KELLER seen by its own ship’s 

physicians and/or other crew members.

153. As such, RCCL voluntarily assumed a duty for the benefit of KELLER to use 

reasonable care in the provision of medical services to KELLER.

154. At all times material hereto, RCCL was careless, negligent, and breached its duties 

due to the fault and/or negligence of RCCL through the acts of its apparent agents by:

a. Failing to promptly provide KELLER with proper medical and/or first aid

care and attention;

b. Failing to timely and properly diagnose and/or assess KELLER’S condition;

c. Failing to timely and properly attend to KELLER, to her injuries, and to her

pain;

d. Failing to provide reasonable medical and/or first aid care;

e. Failing to timely and properly treat and care for KELLER;

f. Failing to timely and properly examine KELLER’S injuries;

g. Failing to take proper measures to secure proper treatment for KELLER, 

including unreasonably delaying taking measures to secure such proper 

treatment;

h. Failing to properly bring and/or arrange for KELLER to be brought to an 

emergency room within a reasonable amount of time; and/or

i. Failing to give KELLER proper discharge instructions; and/or

j. Harming KELLER by improperly twisting her arm; and/or

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k. Unreasonably tightening KELLER’S wrappings for her injuries to an 

unreasonably degree of tightness; and/or

l. Failing to give KELLER adequate pain medicine.

155. At all times material hereto, the aforementioned acts or omissions on the part of 

RCCL fell below the standard of care.

156. RCCL’S negligence proximately caused KELLER great bodily harm in that, but for

RCCL’S negligence, KELLER’S injuries would not have occurred, would have been substantially 

lessened, and/or would not have been aggravated.

157. RCCL, through its employees and agents, to wit, the ship’s medical staff, knew, or 

should have known, that the medical procedures they employed violated reasonable standards of 

medical care.

158. As a result of RCCL’S negligence, KELLER has suffered severe bodily injuries 

resulting in pain and suffering, disability, scarring, disfigurement, mental anguish, loss of 

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

nursing care and treatment, lost wages, and lost earning capacity, and loss of the value of

KELLER’S vacation, cruise, and transportation costs.

159. The losses are permanent and/or continuing in nature.

160. KELLER has suffered these losses in the past and will continue to suffer such loses 

in the future.

WHEREFORE, Plaintiff, RHONDA KELLER, demands Judgment against Defendant, 

ROYAL CARIBBEAN CRUISES, LTD., for damages suffered and costs incurred, as well as for 

damages and costs that KELLER will suffer and incur in the future, as a result of her bodily injury, 

pain and suffering, disability, disfigurement, scarring, mental anguish, hospitalization, medical 

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care and treatment, nursing care and treatment, lost wages, and lost earning capacity, loss of the 

value of KELLER’S vacation, cruise, lost transportation costs, loss of important bodily functions, 

loss of independence, and loss of capacity for the enjoyment of life; for all court costs, pre- and 

post-judgment interest, and for any and all other relief which this Court deems just or appropriate.

DEMAND FOR JURY TRIAL

Plaintiff, RHONDA KELLER, demands trial by jury on all issues so triable.

Dated: July 22, 2022.

Respectfully submitted,

/s/ Matthias M. Hayashi 

Spencer M. Aronfeld, Esq.

Florida Bar No.: 905161

aronfeld@Aronfeld.com 

Abby H. Ivey, Esq.

Florida Bar No.: 1002774

aivey@aronfeld.com

Matthias M. Hayashi

Florida Bar No.: 115973

mhayashi@aronfeld.com

Riana S. Maryanoff, Esq.

Florida Bar No.: 1024768

rmaryanoff@aronfeld.com

ARONFELD TRIAL LAWYERS

One Alhambra Plaza, Penthouse

Coral Gables, Florida 33134

P: (305) 441.0440

F: (305) 441.0198

Attorneys for Plaintiff

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