The Eugene F. Moran
Headline: Harbor collision ruling upholds equal division of damages among vessels at fault, holding each guilty tug or scow equally responsible and preventing joint ownership from reducing individual liability.
Holding:
- Requires each vessel at fault to bear an equal share of collision damages.
- Owning or tying multiple boats together does not reduce an owner’s separate liability.
- Courts may scrutinize whether a missing light actually contributed to the collision.
Summary
Background
A railroad company owned a car-float being towed by a steam tug when it met another tug towing two mud scows. The car-float collided with scow 15 D. The scows 15 D and 18 D lacked required lights, and each scow had an employee who should have shown the light. The tug Moran committed navigation faults and the tug Matthews also shared blame. Two related in-rem suits asked the courts how to split the damage bill among the vessels involved.
Reasoning
The central question was how to divide damages among the vessels that contributed to the collision. The Court said each vessel’s faults were separate, so being tied together or owned by the same person does not make them a single unit. The Court affirmed the District Court’s approach of dividing the loss equally among the guilty vessels, reasoning that separate wrongful acts should produce separate shares of liability. The opinion also noted a question about whether 18 D’s missing light actually helped cause the collision, suggesting that a duty breach that did not produce the harm might not make that boat liable.
Real world impact
Going forward, tugs and towed vessels that contribute to a collision can be held to equal shares of the loss, even when boats are lashed together or owned together. Owners cannot avoid a full share of liability simply because multiple boats belong to them. The Court’s view may prompt closer attention to navigation lights and on-deck responsibilities to avoid being held equally liable.
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