United States v. Reliable Transfer Co.

421 U.S. 397, 95 S. Ct. 1708 (1975)

 

RULE:

When two or more parties have contributed by their fault to cause property damage in a maritime collision or stranding, liability for such damage is to be allocated among the parties proportionately to the comparative degree of their fault, and liability for such damages is to be allocated equally only when the parties are equally at fault or when it is not possible fairly to measure the comparative degree of their fault.

FACTS:

Respondent shipowner brought suit against petitioner United States, under the Suits in Admiralty Act (46 USCS 741 et seq.) and the Federal Tort Claims Act (28 USCS 1346 et seq.), seeking damages caused when respondent’s ship was stranded. The district court apportioned fault for the accident 25% to petitioner for failure to maintain a lighthouse, and 75% to respondent, but divided damages equally between the parties. The appellate court affirmed. Petitioner sought a writ of certiorari. The Supreme Court of the United States vacated the judgment of the appellate court and remanded the case for further proceedings consistent with its opinion.

ISSUE:

Was the appellate court correct in applying the admiralty rule of divided damages, whereby the property damage in a maritime collision or stranding was equally divided whenever two or more parties involved were found to be guilty of contributing fault, regardless of the relative degrees of their fault?

ANSWER:

No.

CONCLUSION:

An equal division of damages was a reasonably satisfactory result only where each vessel's fault was approximately equal, or where proportionate degrees of fault could not be measured and determined on a rational basis. Other countries had long since adopted a comparative fault rule, without difficulty.

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