Empresa Lineas Maritimas Argentinas S.A. v. United States

Chief Warrant Officer Donald Robinson was the captain on the United States Coast Guard cutter Cuyahoga. Robinson had been experiencing continuous respiratory illness for months and repeatedly sought medical care on base. Robinson informed the medical staff that his illness was severely impairing his sleep. Robinson’s condition failed to improve, and base physicians referred him to Walter Reed Hospital for specialty care. Because Robinson was an officer and not an enlisted man, no medical provider declared Robinson unfit for duty, which they would have done for an enlisted man in that condition. Senior officers above Robinson were aware of how often he was seeking care but failed to investigate whether his medical condition could affect his performance of his duties. One day after his third visit to Walter Reed, Robinson made a grave navigational error while captaining the Cuyahoga on a nighttime training operation in the Chesapeake Bay. As a result of this error, the Cuyahoga turned directly in front of the Santa Cruz II, a freighter owned by Empresa Lineas Maritimas Argentinas S.A. (ELMA) (plaintiff). The bow of the Santa Cruz II struck the Cuyahoga, sinking the Cuyahoga within minutes and resulting in the loss of 11 Cuyahoga crew members. ELMA sued the United States (defendant) for damages to the Santa Cruz II. The United States denied liability but asserted that even if it was liable, damages for the collision were limited under 46 U.S.C. § 30505 to the value of the Cuyahoga, which was worthless. The first judge held that Robinson’s error was the sole cause of the collision but that the United States was entitled to limit its liability because it had no knowledge of the events that caused the accident. Before the judgment could be entered, however, the first judge died and a second judge reopened the case. The second judge agreed that Robinson was solely at fault but held that the United States could not limit its liability under § 30505 because persons in the chain of command above Robinson knew or should have known of Robinson’s condition that led to his error. The United States appealed.