The Roman Prince
270 F. 988, 1921 U.S. Dist. LEXIS 1515 (1921)
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Rule of Law:
When a collision occurs between a moving vessel and a stationary vessel, the moving vessel is presumptively at fault, and the burden shifts to it to prove that the collision was not its fault or that the collision could not have caused the resulting damage.
Facts:
- The barge Crane was moored in a slip at the Bush Stores in Brooklyn, loaded with barley.
- On April 19, 1919, the large steamship Roman Prince began maneuvering stern-first out of the same narrow slip, which was approximately 275 feet wide.
- The Prince used its own power and lines attached to the piers to navigate past the Crane and other moored vessels.
- Multiple eyewitnesses, located on nearby barges and the pier, observed the stern of the Prince strike the Crane a severe blow on its starboard side, near amidships.
- Mrs. Keenan, the wife of the Crane's captain who was aboard the barge, called out to an officer on the Prince that their vessel had sunk her boat.
- Within 5 to 10 minutes of the Prince passing, the Crane was observed to be sinking.
- The Crane became completely submerged approximately 30 minutes after the Prince had cleared the slip.
- A subsequent underwater examination by a diver revealed damage to the Crane's stern planks, but no visible damage at the amidships point where witnesses reported the impact.
Procedural Posture:
- The owner of the barge Crane, as libelant, filed a libel in admiralty against the steamship Roman Prince in the United States District Court.
- The case proceeded to a trial before the court, which heard testimony from witnesses for both parties.
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Issue:
Is a moving vessel liable for damages to a stationary vessel when multiple disinterested eyewitnesses testify that a collision occurred, even though the moving vessel's crew denies contact and the physical evidence of damage is not perfectly consistent with the eyewitness accounts?
Opinions:
Majority - Chatfield, District Judge
Yes. A moving vessel is liable for damages when credible eyewitness testimony establishes a collision with a stationary vessel, creating a presumption of negligence that the moving vessel must rebut. The court found the testimony of the disinterested eyewitnesses to be more credible and persuasive than the denials from the Prince's crew, who had an interest in the outcome. Despite inconsistencies between the reported point of impact and the damage found by the diver, the court concluded that a collision did occur. Once the fact of the collision was established, the burden shifted to the Prince to show it was not at fault or that the contact could not have caused the sinking. Because damage would almost inevitably result from such a contact, and the Prince failed to rebut the presumption of negligence, it was held liable for the damages.
Analysis:
This case exemplifies a fundamental principle of admiralty law, often referred to as the Oregon Rule, which establishes a strong presumption of fault against a moving vessel that strikes a stationary object. The decision underscores the significant weight courts may give to the testimony of disinterested eyewitnesses, even when it conflicts with physical evidence or the testimony of a vessel's crew. This ruling reinforces that once a collision is proven, the legal burden shifts dramatically, requiring the moving vessel to provide a compelling explanation to escape liability. It serves as a precedent for holding large, powerful vessels to a high standard of care when maneuvering in confined waterways.
