Union Oil Co. of Cal. v. the San Jacinto
Headline: Court narrows fog-speed "half-distance" rule and overturns the appeals court, making the tug and barge solely responsible while the oil tanker is cleared of shared blame.
Holding: The Court reversed the Ninth Circuit and held the tanker not liable, finding respondents alone at fault and therefore did not reach the damages question.
- Narrows when the half-distance fog-speed rule applies to nearby vessels.
- Makes the tug and barge fully liable while the tanker is cleared of shared fault.
- Leaves the question of dividing damages between both vessels unresolved.
Summary
Background
An oil tanker was moving upriver on the Oregon side of a narrow channel when a tug towing a large barge on the Washington side entered a localized fog bank. The tug executed an unexpected U-turn in the fog and the barge swung into the tanker, causing damage. The tanker sued for repairs and the barge owner cross-claimed. The trial court blamed only the tug and barge; the Court of Appeals found the tanker partly at fault under a traditional fog-speed rule and split liability.
Reasoning
The key question was whether the long-standing "half-distance" rule—requiring a ship in fog to go slow enough to stop within half the visible distance—applied on these facts. The Court said that rule rests on a realistic possibility that two vessels will meet on intersecting courses. Here the vessels were on opposite sides of a narrow but well-defined channel, the tanker had clear visibility ahead, and the tug made an unorthodox, unforeseeable maneuver. Because that scenario was not the danger the half-distance rule was meant to prevent, the Court reversed the appeals court and held the tug and barge solely at fault. The Court did not decide how damages should be split in cases where both vessels share blame.
Real world impact
The decision narrows when the half-distance rule automatically applies. Mariners and shipowners should note that courts may look to whether an intersecting course was a realistic possibility before finding statutory fault for speed in fog. The ruling leaves unresolved the separate question of how to divide damages when both vessels are at fault.
Dissents or concurrances
A dissent argued the half-distance rule should remain a clear, measurable safety rule and that the tanker could still be partly at fault for proceeding near the fog bank at half speed.
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