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Law School Case Brief

Exxon Co. v. Sofec - 517 U.S. 830, 116 S. Ct. 1813 (1996)

Rule:

The doctrine of superseding cause is applied where defendant's negligence in fact substantially contributed to plaintiff's injury, but the injury was actually brought about by a later cause of independent origin that was not foreseeable. It is properly applied in admiralty cases.

Facts:

Petitioner filed a complaint in admiralty against respondents for the loss of its ship and cargo based upon the theories of breach of warranty, strict products liability, and negligence. Petitioner's ship was engaged in delivering oil into a pipeline through two floating hoses when a heavy storm broke the chafe chain linking the vessel to the single point mooring. Petitioner's tanker broke away from a single point mooring system owned and operated by respondents, who then claimed that the conduct of petitioner's ship captain was the superseding and sole proximate cause of the loss of the ship. The district court ruled against the petitioner.

Issue:

Does the doctrine of superseding cause apply in favor of the petitioner?

Answer:

No.

Conclusion:

The court affirmed the decisions of the lower courts and held that petitioner was the superseding and sole proximate cause of its own injury. The finding that petitioner's extraordinary negligence was the sole proximate cause of its own injury cut off respondents' liability for that injury on a contractual breach of warranty theory as well.

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