United States v. M/v Big Sam, in Rem

681 F.2d 432, 17 ERC 2169, 12 Envtl. L. Rep. (Envtl. Law Inst.) 20994, 17 ERC (BNA) 2169, 1982 U.S. App. LEXIS 16944
CourtCourt of Appeals for the Fifth Circuit
DecidedJuly 30, 1982
Docket81-3127
StatusPublished
Cited by37 cases

This text of 681 F.2d 432 (United States v. M/v Big Sam, in Rem) 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
United States v. M/v Big Sam, in Rem, 681 F.2d 432, 17 ERC 2169, 12 Envtl. L. Rep. (Envtl. Law Inst.) 20994, 17 ERC (BNA) 2169, 1982 U.S. App. LEXIS 16944 (5th Cir. 1982).

Opinion

TATE, Circuit Judge:

The United States appeals from the dismissal of its suit against the Motor Vessel BIG SAM and its owner to recover oil spill cleanup costs. It is conceded that the sole fault of the accident was the negligent operation of the BIG SAM, which struck a tanker barge and caused the discharge of substantial quantities of oil. The district court held that liability for the cleanup costs was exclusively governed by section 311(g) of the Federal Water Pollution Control Act [“the Act”], 33 U.S.C. § 1321(g), and that under this section the sole party responsible was the insolvent bareboat charterer of the BIG SAM.

We reverse, holding (1) that both owner and charterer of the sole-fault, non-discharging vessel are liable under § 1321(g), (2) that this statutory section does not exclude an in rem remedy, and (3) that any maritime tort remedy of the United States against the negligent vessel is not preempted by § 1321(g), in view of the express provision of 33 U.S.C. § 1321(h)(2) that the liabilities established by the Act “shall in no way affect any rights which . . . the United States Government may have against any third party whose actions may in any way have caused or contributed to the discharge of oil or hazardous substance.”

Factual Context of the Issues

The case originated out of a collision in the Mississippi River between the M/V BIG SAM and the T/B BUTANE, April 25,1975, which resulted in hull damages to and oil spill from the BUTANE. The BIG SAM is a twin screw towboat, 155 gross tons, which at the time of the collision was owned by Zito Towing, Inc. and bareboat chartered by Tri-Capt, Inc. Due to negligent navigation and an inexperienced pilot, the BIG SAM collided with the tank barge BUTANE, owned and operated by Delta Barge Line. The collision caused 280,000 gallons of oil to be discharged from the BUTANE. Delta Barge Line immediately began cleanup operations. After spending over $50,000 in cleaning up and protecting water intakes, Delta turned the operation over to the U. S. Coast Guard, which spent almost $300,000 more to finish cleaning up the spill.

The United States brought this suit against the BIG SAM (in rem), Zito (its owner), and Tri-Capt (the vessel’s bareboat charterer), 1 alleging causes of action based upon (a) § 1321(g) of the Act, (b) the Refuse Act, 33 U.S.C. § 407, and (c) general negligence (maritime tort law), to recover its cleanup costs. The findings in litigation between the private parties were stipulated, 2 under which the sole cause of the collision was the negligence of the BIG SAM, *435 the non-discharging third-party vessel. The district court held that liability was determined exclusively by § 1321(g); that under that section no in rem remedy against the vessel was recognized; and that under § 1321(g) Tri-Capt, the bareboat charterer (by now insolvent), was solely at fault and that it alone was thus liable in the amount of $15,500, the limit of liability under the circumstances as provided by § 1321(g). 3

The government contends that the district court erred in not affording an in rem remedy against the solely negligent vessel, and in its holding that § 1321(g) of the Act provided the exclusive remedy against a third-party non-discharging vessel solely at fault. Before reaching these contentions, we will set forth briefly an overview of sections of the Act relevant to the issues before us.

The Statutory Scheme

The issues before us on this appeal are essentially ones of statutory construction. Involved are not only what remedies were intended by Congress in passing the Act, but as well what remedies were foreclosed.

The Act, 33 U.S.C. §§ 1251-1376, was originally enacted as the Water Quality Improvement Act of 1970, Pub.L.No.91-224, with relevant provisions reenacted as part of the Federal Water Pollution Control Act Amendments of 1972. 4 The Act prohibits the discharge of oil into the navigable waters of the United States, 33 U.S.C. § 1321(b)(1). The government is authorized to clean up any oil spill not properly removed by the discharger, 33 U.S.C. § 1321(c)(1), including the emergency power to remove, and if necessary destroy, the discharging vessel, 33 U.S.C. § 1321(d).

The Act imposes liability for cleanup costs on “dischargers,” and cleanup costs incurred by the government are recoverable under § 1321(f)(1), (2), (3) 5 from the discharging vessel or facility. If, however (as *436 here), the sole cause of the accident is the act or omission of a third party, the government is permitted to recover its cleanup costs from such sole-cause third-party. § 1321(g) 6 . The Act also expressly pro *437 vides that the liabilities thereby provided “shall in no way affect any rights” that a discharging vessel or facility, or the United States, may have against any third party whose acts “may in any way have caused or contributed to the discharge.” § 1321(h) (emphasis supplied). 7

A primary issue of this appeal is the interrelationship between subsections (f), (g), and (h), with regard to the liability of a sole-cause non-discharging vessel. These subsections, as re-enacted in 1972 by the Act, are essentially the same as those originally enacted by section 11(f), (g), and (h) of the Water and Environmental Quality Improvement Act of 1970, Pub.L. 91-224, 84 Stat. 91. Committee reports 8 and debates relating to the enactment of these predecessor provisions have been considered as the source of the legislative history of these subsections (f), (g), and (h), although the 1972 committee reports also referred to them without illuminating expression. 9

Subsection (f) imposes a strict liability standard under which the United States may recover from a discharger its cleanup costs up to stated limits without a showing of fault. The discharger may, however, escape this strict liability if he shows that the discharge was caused solely by an act of God, an act of war, negligence on the part of the United States — or an act or omission of a third party.

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Bluebook (online)
681 F.2d 432, 17 ERC 2169, 12 Envtl. L. Rep. (Envtl. Law Inst.) 20994, 17 ERC (BNA) 2169, 1982 U.S. App. LEXIS 16944, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-mv-big-sam-in-rem-ca5-1982.