Exxon Company, U. S. A. v. Sofec, Inc.

517 U.S. 830 (1996)

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Nature of the Case

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Facts

The Exxon Houston was using a Single Point Mooring System (SPM) owned and operated and manufactures by Ds to deliver oil. A heavy storm broke the chafe chain linking the vessel to the SPM. the oil hoses broke away from the SPM. The hoses were bolted to the ship, and a portion of the second hose remained attached to the ship. So long as the hose was attached to and trailing from the ship, it threatened to foul the ship's propeller, and consequently, the ship's ability to maneuver was restricted. Captain Coyne, took the ship through a series of maneuvers and was able to get control of the end of the hose so that it was no longer a threat to the Houston. Between 1803 and 1830, Captain Coyne maneuvered out to sea and away from shallow water. By 1830, the Houston had successfully avoided the peril resulting from the breakout. Many of Captain Coyne's actions after 1830 were negligent. Captain Coyne failed to have someone plot the ship's position between 1830 and 2004. The courts found that this failure to plot fixes of the ship's position was grossly and extraordinarily negligent. At 1956, Captain Coyne initiated a final turn toward the shore. He ordered another crew member to plot the fix at 2004. The ship was headed for a reef. The ship ran aground, resulting in its constructive total loss. The District Court found that Captain Coyne's decision to make this final turn 'was not foreseeable.' P sued Ds for the loss of its ship and cargo in breach of warranty, strict products liability, and negligence. The District Court found that Captain Coyne's (and by imputation, P's) extraordinary negligence was the superseding and sole proximate cause of the Houston's grounding. P appealed. The Court of Appeals rejected P’s contention that the captain's actions were foreseeable reactions to the breakout; rather, it noted, Captain Coyne himself had explained that he did not plot fixes 'because he felt it was unnecessary to do so.' The court rejected P's legal argument that the doctrines of proximate causation and superseding cause were no longer applicable in admiralty in light of this Court's decision in Reliable Transfer. An intervening force supersedes prior negligence' and thus breaks the chain of proximate causation required to impose liability on the original actor, the court held, 'where the subsequent actor's negligence was 'extraordinary' (defined as 'neither normal nor reasonably foreseeable').' The Supreme Court granted certiorari.