Postal SS Corp. v. El Isleo

Background

A collision occurred in Baltimore Harbor when the steamship Eastern Glade crossed into Fort McHenry Channel and struck the steamer El Isleo. Each vessel’s owner sued the other. The District Court found Eastern Glade solely at fault and the Second Circuit affirmed. The Supreme Court accepted review because the case raised an important maritime law question about whether two local pilot rules (Rules II and VII of the Board of Supervising Inspectors) are valid alongside certain federal Inland Rules created by Congress.

Reasoning

The Court asked whether the Inspectors' Rules — one banning “cross signals” and another directing ships to stop and back if signals cause misunderstanding — conflict with Articles 19, 21–23, and 27 of the Inland Rules. Reading the rules together, the Court carefully concluded they are consistent: the statutory “privileged” ship may not insist on keeping course and speed when its continuing would create a danger. Article 27 allows departures to avoid immediate danger, so the Inspectors could sensibly require stoppage and backing to prevent collisions. The Court reversed and sent the case back so the appeals court could reconsider the facts using the inspectors' rules.

Real world impact

The ruling clarifies that local inspectors can adopt safety rules that require stopping and backing to avoid collision dangers. Ship masters must yield their statutory privilege when continuing creates real risk. The decision resolves conflicting Second Circuit practice and leaves the actual fault allocation in this collision to be determined on remand.