## Facts

- Wesley Brown (plaintiff) worked for Channel Fueling Service, Inc. (Channel Fueling) on the fuel barge **CHANNEL FUELER 10**.
- Gremar Compania (Gremar) (defendant) owned the tanker **M/T APHRODITE B**; Nola Marine (defendant) owned the tug **KAREN WAYNE**.
- On September 5, 1981, **APHRODITE B** and **KAREN WAYNE** collided on the Mississippi River, spilling heavy crude oil into the river.
- Brown was working about **six miles downstream** from the collision site.
- The parties stipulated that oil from the spill **reached CHANNEL FUELER 10 about six hours after the collision**, washed onto the deck, and **congealed into a soft, tar-like substance**.
- Brown’s regular job duties included **cleaning the barge’s deck**.
- Two days after the collision, while cleaning most of the oil from the deck, Brown **lost his footing and fell**, sustaining injuries.
- Brown sued Channel Fueling, Gremar, and Nola Marine for negligence.
- Gremar moved for **summary judgment**, arguing that even if the collision and spill were negligent to some persons, Gremar **owed no duty to Brown for this type of harm** and its conduct was not the **legal (proximate) cause** of Brown’s slip-and-fall.

## Issues

1. Whether, under federal maritime negligence principles, the tanker owner’s role in a collision and oil spill was the legal/proximate cause of a worker’s slip-and-fall that occurred **two days later** on a barge **six miles downstream** while the worker cleaned congealed oil.
2. Whether the risk that a downstream worker might later slip while cleaning residual oil fell within the duty owed by the tanker owner arising from the collision and spill.

## Decision

- The court **granted Gremar’s motion for summary judgment**.
- The court held that, on the undisputed and stipulated facts, Gremar’s conduct was **not the legal cause** of Brown’s injury and did not support negligence liability to Brown for this event.
- The ruling disposed of Brown’s claims against **Gremar** in this opinion; claims involving other defendants were not resolved here.

## Legal Principles

- Liability for negligence in admiralty requires more than factual cause; the plaintiff must show a duty and that the injury is sufficiently connected to the defendant’s conduct to qualify as **legal (proximate) cause**.
- “Legal cause” functions as a limit on negligence liability: even if an act contributes in fact to an injury, the law may treat the harm as too remote where the risk and the injury are outside the range of harms for which the defendant is responsible.
- A defendant’s general obligation to act with reasonable care is not a boundless duty to all persons for all downstream consequences; courts evaluate whether the plaintiff’s harm is within the class of risks tied to the defendant’s alleged negligence.
- When material facts are undisputed (including by stipulation), a court may decide duty/legal-cause limits **as a matter of law** on summary judgment.

## Conclusion

In **Brown v. Channel Fueling Service, Inc.**, the Eastern District of Louisiana granted summary judgment to the tanker owner, concluding that an oil spill from a river collision—though a factual source of oil that later coated a downstream barge—was too remote in time, distance, and circumstances to make the tanker owner legally responsible for a worker’s slip-and-fall two days later during routine deck cleaning.


Brown v. Channel Fueling Service, Inc., 574 F. Supp. 666 (1983)