Frank W. Cates, Cross-Appellant v. United States of America, Cross-Appellees

451 F.2d 411, 1971 U.S. App. LEXIS 7976
CourtCourt of Appeals for the Fifth Circuit
DecidedSeptember 20, 1971
Docket29874
StatusPublished
Cited by55 cases

This text of 451 F.2d 411 (Frank W. Cates, Cross-Appellant v. United States of America, Cross-Appellees) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frank W. Cates, Cross-Appellant v. United States of America, Cross-Appellees, 451 F.2d 411, 1971 U.S. App. LEXIS 7976 (5th Cir. 1971).

Opinion

JOHN R. BROWN, Chief Judge:

In an appeal which for the most part ignores the distinctive role of this Court as though the balmy pre-McAllister 1 days of reconsideration of admiralty cases de novo were still the birthright of proctors who have also lost their title (see O/Y Finlayson-Forssa A/B v. Pan Atlantic S.S. Corp., 5 Cir., 1958, 259 F. 2d 11, 13, 1958 A.M.C. 2070, 2071; Higgins, Inc. v. Hale, 5 Cir., 1958, 251 F.2d 91, 92, 1958 A.M.C. 646, 647), this case does have two things of special interest.

The first is that what is admittedly a little ease arose from a big crisis. Although then unknown to countless embassies, foreign ministers and highly placed world leaders, Frank Cates’ fall into a misused Navy whaleboat grew out of the world’s tensions when a mid-air collision involving an American Air Force bomber dropped an awesome H-bomb into the waters off the coast of Palamores, Spain, in January 1966. Task Force 65 was formed by the United States Navy to retrieve the bomb and relieve the world. Cates’ role was that of a member of the deep-diving submarine, ALUMINAUT, owned and operated by his employer Reynolds. 2 For towage of ALUMINAUT and transfer of her crew to another government vessel used to quarter and victual them, the USS NIMBLE was assigned. Though no one suggests it by way of attack or defense, one could suppose that the critical nature of this international mission electrified the air.

Second, and more juridically important, the Trial Judge, who can truly be called learned for his prescience, sounded this high note: “A distinguished feature of Anglo-Saxon jurisprudence is its ability to change when confronted with an unjust result dictated by existing law. In this case there was an occurrence which I find would work such an injustice and I accordingly hold contrary to the existing weight of authority.” Whether the course was as bold and precarious as thought, or whether existing principles surrounding those who go down to sea in ships — way down — would have just as readily rejected the Government’s harsh plea is not now important. What is important is that the Judge proved his seaworthiness 3 by anticipating the “release from the release” at the hands of the Supreme Court in Zenith Radio Corp. v. Hazeltine Research, Inc. 4

In more austere language, this was the case. Frank W. Cates brought suit against the United States and Reynolds claiming damages for injuries suffered while debarking from the USS NIMBLE into a whaleboat alongside for transportation back to the quartering vessel. On the eve of trial, Cates settled his claim with Reynolds and executed a release in their behalf and their vessels’. Upon hearing the case, the District Court entered judgment against the United States in the amount of $8,000 less amounts paid to Cates by Reynolds in consideration of the release, 308 F.Supp. 199. We affirm.

Only two questions are really presented by this appeal: (i) Does a seaman’s release which does not specifically reserve rights against another joint tort-feasor operate to release the unmentioned joint tortfeasor as a matter of law? (ii) Was Cates entitled to a warranty of seaworthiness?

*413 I. The Red Letter Release

On the date originally set for trial, all parties appeared and it was announced that Plaintiff had reached a settlement agreement with Reynolds. Plaintiff announced ready to proceed against the Government, but the Government sought and obtained a continuance. 5 Shortly thereafter, Plaintiff executed a formal written release of Reynolds, which was in everything but color a red letter release which virtually indentured Cates’ future to the parties named. 6 When the case came up for trial a month later, the Government argued for the first time that failure to reserve rights against it expressly in the release operated to absolve the United States from liability.

The Government relies on the general common law rule that the release of one joint tortfeasor operates to release all tortfeasors unless the written instrument contains an express reservation of rights against others. See, e. g., Canil-las v. Joseph H. Carter, Inc., 280 F. Supp. 48 (S.D.N.Y.1968); Restatement of Torts § 885(1); Prosser, Torts, (3d Ed), pages 268-272.

This argument, even if it validly states the general common law rule — and that if is a very big one 7 — overlooks two *414 things. The first is the role of the Court in admiralty. Over a century ago this high calling was vividly described by Justice Story. “A court of admiralty is, as to all matters falling within its jurisdiction, a court of equity. Its hands are not tied up by the rigid and technical rules of the common law, but it administers justice upon the large and liberal principles of courts which exercise a general equity jurisdiction.” The David Pratt F.Case No. 3597 (D.C. Maine 1839). And as we have more recently expressed it, “The Chancellor is no longer fixed to the woolsack. He may stride the quarter-deck of maritime jurisprudence and, in the role of admiralty judge, dispense, as would his landlocked brother, that which equity and good conscience impels.” 8

Second, a release of a seaman— long called the “ward of the Admiralty” 9 — is precarious, at best, and the burden is on the party setting up the seaman’s release to show that it was given by the seaman with an informed understanding of his rights and a full appreciation of the consequences of his release. 10

*415 If courts of admiralty can refuse to enforce an unjust release in favor of the party purportedly discharged (see, e. g., Bonici v. Standard Oil Company, 2 Cir., 1939, 103 F.2d 437), it follows that the Admiralty has like equitable latitude in declining to enforce, not the release itself, but the antiquated, unreasoned, technical rule in favor of one not even mentioned as a party.

But apart from the two factors of (i) equitable powers of the Admiralty and (ii) the vulnerability of a seaman’s release, we are freed at last of this anachronistic and rigid rule of the common law — certainly in cases relating to injuries to seamen, amphibious ambiguous seamen included — by the Supreme Court’s ruling in Hazeltine (see note 4, supra).

There the Court, after delineating the three rules which have emerged in cases of this kind, 11

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Bluebook (online)
451 F.2d 411, 1971 U.S. App. LEXIS 7976, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frank-w-cates-cross-appellant-v-united-states-of-america-ca5-1971.