Holzhauer v. Golden Gate Bridge District

Tort liability for joint operation of a vessel is determined proximate to the time of the accident, not through the duration of the voyage.  The boat owner therefore had no duty to supervise the skilled passenger under a duty of joint operation when the latter took the helm, and as there was no duty of care, no question of comparative negligence arises.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/08/10/16-15942.pdf