## Facts

- On January 7, 1994, the tug M/V EMILY S towed the barge MORRIS J. BERMAN, carrying fuel oil, off San Juan, Puerto Rico.
- The towing wire parted, the barge grounded off Punta Escambrón, and a large quantity of fuel oil spilled into Puerto Rico’s waters.
- The Commonwealth of Puerto Rico sued entities associated with the tug and barge for spill-related damages under the Oil Pollution Act of 1990 (OPA), maritime law, and Puerto Rico law; the United States and private claimants also asserted spill-related claims.
- Within six months of the casualty, the vessel interests filed limitation proceedings under the Limitation of Shipowner’s Liability Act of 1851 and invoked Supplemental Admiralty Rule F seeking exoneration or limitation.
- The district court issued a monition enjoining other actions against the limitation plaintiffs for claims arising from the grounding, except as filed in the limitation proceedings.
- Claimants argued that OPA displaced the Limitation Act and Rule F as to OPA removal-cost and damages claims; the district court agreed, and the vessel interests appealed.

## Issues

1. Whether OPA removal-cost and damages claims are subject to the Limitation Act’s substantive limitation of liability.
2. Whether OPA removal-cost and damages claims may be compelled into a Rule F concursus and related limitation-proceeding mechanisms.

## Decision

- The First Circuit affirmed.
- The court held that OPA claims for removal costs and damages are not subject to the Limitation Act’s substantive limitation of liability.
- The court held that OPA claims for removal costs and damages are not subject to Rule F concursus or the Limitation Act’s procedural framework.
- The limitation plaintiffs could not use limitation proceedings to cap or centralize OPA removal-cost and damages claims.

## Legal Principles

- When Congress enacts a detailed, specific liability and limitation regime for a defined category of harm, that regime controls over an older, general maritime limitation statute to the extent of conflict.
- OPA supplies an integrated framework for oil-spill liability, defenses, and statutory caps for “responsible parties,” which is inconsistent with vessel-value limitation under the Limitation Act for the same removal-cost and damages claims.
- Rule F concursus and injunction practice may not be used to restructure or delay OPA’s statutory claims process for removal costs and OPA-defined damages.
- The Limitation Act remains available, if at all, only for maritime claims not governed by OPA’s removal-cost and damages provisions.

## Conclusion

The First Circuit held that OPA’s statutory scheme governs oil-spill removal-cost and damages claims and therefore precludes both Limitation Act liability limitation and Rule F concursus for those OPA claims arising from the Puerto Rico spill.


Complaint of Metlife Cap. Corp., 132 F.3d 818 (1st Cir. 1997)