The John G. Stevens
18 S. Ct. 544, 170 U.S. 113, 1898 U.S. LEXIS 1532 (1898)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A maritime lien for damages arising from a tort, such as a collision caused by negligent towage, takes priority over a pre-existing statutory lien for supplies based on contract. A claim by a tow against its tug for damages from such negligence is considered a claim in tort (ex delicto), not contract (ex contractu).
Facts:
- James G. Stevens and others furnished supplies and repairs to the steam-tug John G. Stevens in her home port, creating a statutory lien on the vessel.
- Subsequently, the John G. Stevens was engaged in towing the schooner C. R. Stone.
- Due to the negligence of the John G. Stevens, its tow, the C. R. Stone, collided with another vessel, the schooner-barge Amboy.
- The C. R. Stone sustained damages as a result of the collision caused by the tug's negligence, creating a maritime lien on the John G. Stevens for those damages.
Procedural Posture:
- The owners of the schooner C. R. Stone filed a libel in rem in the U.S. District Court for the Eastern District of New York against the steam-tug John G. Stevens.
- James G. Stevens and others intervened in the proceeding, asserting a prior statutory lien for supplies furnished to the tug.
- The District Court ruled in favor of the intervenors, holding that the lien for supplies was entitled to priority over the lien for damages from negligent towage.
- The owners of the C. R. Stone, as libelants, appealed the District Court's decree to the U.S. Circuit Court of Appeals for the Second Circuit.
- The Circuit Court of Appeals, facing conflicting precedents, certified the question of lien priority to the Supreme Court of the United States for a definitive ruling.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a maritime lien for damages caused by a tug's negligent towage, which resulted in a collision, have priority over a prior statutory lien for supplies furnished to the tug before the collision occurred?
Opinions:
Majority - Mr. Justice Gray
Yes, a subsequent maritime lien for damages from a tort takes priority over a prior lien for supplies based on contract. The court's reasoning rests on two key determinations. First, a lien for collision damages is superior to prior contract-based liens. The court adopts the 'personification of the vessel' doctrine, treating the ship itself as the wrongdoer. Under this principle, all prior interests in the ship, including liens for supplies, are subordinate to the lien created by the ship's subsequent tortious act. Those holding prior liens are analogized to part-owners whose interests are subject to the risks of navigation, including liability for the vessel's negligence. Second, the court classifies the claim of a tow against its tug for negligent towage as a tort claim (ex delicto). While a contract for towage creates the relationship, the duty to exercise reasonable care is imposed by law, and its breach constitutes a tort, not merely a breach of contract. Citing precedent like The Quickstep, the court affirms that such a lawsuit is for the 'commission of a tort.' Therefore, because the lien for negligent towage is a tort lien, it is entitled to priority over the earlier contract-based lien for supplies.
Analysis:
This decision solidifies the priority of tort liens over prior contract liens in American admiralty law, significantly impacting maritime commerce. By affirming the 'personification of the vessel' doctrine, the Court established that a ship's creditors assume the risk that their security interest may be subordinated to claims arising from the vessel's future negligence. The case also definitively categorizes negligent towage claims as torts, granting them a privileged status. This holding incentivizes safe navigation and prioritizes the compensation of tort victims over commercial creditors, shaping risk allocation for maritime insurers, suppliers, and financiers.
