Exxon Co., USA v. Sofec, Inc.

Background

A shipping company, Exxon, was offloading oil through floating hoses attached to a Single Point Mooring (SPM) owned and run by pipeline companies and made by a manufacturer. A storm broke the chain holding the tanker to the SPM and the hoses parted; one hose stayed bolted to the ship and restricted its maneuvering. The captain later took many actions, and by 1830 the ship had reached a safe position. During the next hours the crew failed to plot the ship’s position while working to disconnect the hose. At about 1956 the captain turned toward shore without knowing the ship’s location, and after a late position fix the ship ran aground and was lost. The District Court found the captain’s later conduct grossly and extraordinarily negligent and the sole proximate cause of the grounding; the Ninth Circuit affirmed.

Reasoning

The Court held that admiralty law still requires legal or “proximate” causation and that the related doctrine of superseding cause applies, even after this Court adopted comparative fault in Reliable Transfer. The Court explained that a later, independent, and unforeseeable negligent act can cut off liability for earlier actors. Because the lower courts found the captain’s extraordinary negligence to be the superseding and sole legal cause, the Court affirmed that Exxon could not recover in tort or on warranty theories from the SPM owner or the hose manufacturer. The Court also found the trial court’s bifurcation of causation issues was not an abuse of discretion.

Real world impact

The decision means that in maritime accidents a shipowner’s own extraordinary crew negligence can bar recovery from other parties even when their acts were causes in fact. It also limits recovery on breach-of-warranty claims when legal causation is lacking. Factual findings about negligence receive only limited appellate review, so trial courts’ causation findings are decisive in many cases.