Farrell Lines, Inc. v. Jones

Farrell Lines, Inc. (Farrell) (defendant) owned a steamship, which was traveling down a river at night. As required by Farrell’s operating manual, five crew members staffed the bridge of the ship: a master, a helmsman, two pilots, and a watch officer. This level of staffing was generally considered adequate among maritime professionals. As part of his duties, the watch officer was required to be continually available to oversee the helmsman’s work. The watch officer’s other duties were minor enough so as to make this availability possible. This level of oversight was also generally considered adequate among maritime professionals. The ship was equipped with a lighted dial that indicated the rudder’s position. The indicator was located where it could be checked by both the helmsman and the watch officer without undue inconvenience. As the ship approached a drawbridge, the helmsman incorrectly executed a steering order to move the rudder to the left by moving the rudder to the right instead. Six seconds later, a third mate noticed the error and alerted the crew. Despite emergency measures, the ship ran into the bridge. Ten people died, and an additional 10 were injured. Victims of the accident (plaintiffs) filed claims against Farrell. Farrell petitioned the district court for a ruling that its liability was limited under the Limitation Act. The district court denied the petition, finding that Farrell’s procedures should have included a fail-safe. Farrell appealed.