In Holzhauer v. Rhoades (2018 9th Cir.) 2018 WL 3795779, the Ninth Circuit Court of Appeals held that a boat owner who is a passenger on his boat has no duty to keep a lookout unless the owner-passenger knows that the person operating his boat is likely to be inattentive or careless or the owner-passenger was jointly operating the boat at the time of the accident. The joint operation is not viewed over the course of the entire trip, but instead at the time immediately preceding and concurrent with the accident.