No. The company that made the faulty mooring chain doesn't have to pay. The court said that the law has a rule called 'superseding cause.' It means that even if someone's initial mistake (like the weak chain) is a 'but-for' cause of what happened, they are not responsible if a later event was so crazy and unforeseeable that it becomes the new, primary cause of the accident. Here, the captain had already solved the first problem and reached safety. His decision to stop navigating and turn blindly toward a reef was a brand-new, independent, and 'extraordinarily negligent' mistake. This new mistake broke the 'chain of blame' leading back to the original broken chain.

Yes, the rule about overriding mistakes applies here. We're saying that even though we've changed some rules about how to divide blame in ship accidents, the old rules about one person's big mistake canceling out other people's smaller mistakes still work. The captain's very unexpected and extreme carelessness was the main reason for the accident, which means the other parties involved in the initial problem are not legally at fault. This is fair because we can't blame people for things they couldn't have seen coming. We're not going to change what the lower courts decided about the facts of the case because they didn't make any big, obvious mistakes in figuring out what happened.

No. The adoption of comparative fault in United States v. Reliable Transfer Co. did not eliminate the fundamental requirement of proximate causation in admiralty law. A system that apportions damages based on comparative fault is not inconsistent with the principle that liability only attaches to tortfeasors whose actions were a proximate cause of an injury. The superseding cause doctrine is a facet of proximate cause which operates to cut off the liability of a negligent defendant when an injury is actually brought about by a subsequent, unforeseeable cause of independent origin. Where a plaintiff's own extraordinary negligence is found to be the superseding and sole proximate cause of its harm, that negligence breaks the chain of causation from the defendant's initial fault, barring any recovery for the plaintiff. This principle applies equally to claims of negligence and breach of warranty.

Yes. The doctrine of superseding cause does apply in admiralty law. I affirm that the requirement of legal or 'proximate' causation, and the related 'superseding cause' doctrine, apply in admiralty notwithstanding our adoption of the comparative fault principle in United States v. Reliable Transfer Co. The extraordinary negligence of Captain Coyne, which was neither normal nor reasonably foreseeable, acted as a superseding cause that absolved the defendants of liability for the breakout or provision of safe berth after the breakout. This decision aligns with the principles of proximate causation which are necessary limitations on liability and are compatible with the comparative fault system. We reject Exxon's argument that the superseding cause doctrine should not apply in admiralty cases. There is nothing internally inconsistent in a system that apportions damages based upon comparative fault only among tortfeasors whose actions were proximate causes of an injury. The finding that Captain Coyne's extraordinary negligence was the sole proximate cause of Exxon's injury suffices to cut off respondents' liability for that injury on both tort and contractual breach of warranty theories. We decline to reconsider the lower courts' factual findings regarding proximate causation, as Exxon has not made an 'obvious and exceptional showing of error' that would justify our reversal of their ultimate conclusion.

Exxon Co. v. Sofec, Inc.

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