OCTOBER TERM, 1995
certiorari to the united states court of appeals for the ninth circuit
No. 95-129. Argued March 19, 1996—Decided June 10, 1996
Petitioner Exxon's oil tanker, the Exxon Houston, ran aground and was lost several hours after its "breakout" from a mooring facility owned and operated, or manufactured, by the various respondents. Exxon filed a complaint in admiralty against respondents, alleging, inter alia, negligence and breach of warranty. In granting respondents' motion to bifurcate the trial, the District Court limited the first phase thereof to the question whether the postbreakout conduct of the Houston's captain, Captain Coyne, was the superseding and sole proximate cause of the loss of the ship, leaving the issue of causation of the breakout itself for the second phase. After a bench trial, the court found that Captain Coyne's (and by imputation, Exxon's) extraordinary negligence was indeed the superseding and sole proximate cause of the Houston's grounding, and entered final judgment against Exxon. The Ninth Circuit affirmed. Among other things, it rejected Exxon's legal argument that the doctrines of proximate causation and superseding cause are no longer applicable in admiralty in light of United States v. Reliable Transfer Co., 421 U. S. 397, in which this Court abandoned the "divided damages" rule previously applied in admiralty and adopted the comparative fault principle for allocating damages among responsible parties; held that the District Court's causation findings were well supported by the record and not clearly erroneous; ruled that the lower court did not err in rendering judgment against Exxon on its breach of warranty claims; and concluded that, under the circumstances, the bifurcation of the trial was not an abuse of discretion.
Held: A plaintiff in admiralty that is the superseding, and thus the sole proximate, cause of its own injury cannot recover part of its damages from tortfeasors or contracting partners whose blameworthy actions or breaches were causes in fact of the plaintiff's injury. Pp. 836-842. (a) The Court rejects Exxon's primary argument that the proximate causation requirement, and the related superseding cause doctrine, are not or should not be applicable in admiralty. The Court finds unpersuasive Exxon's assertion that the lower courts' refusal to allocate any share of damages to parties whose fault was a cause in fact of its injury conflicts with Reliable Transfer. The proximate causation requirement was not before the Court in that case, and the Court did not suggestPage: Index 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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