## Facts

- Farrell Lines, Inc. owned the steamship *AFRICAN NEPTUNE*, which departed Brunswick, Georgia, at night and proceeded downriver toward the open draw of the Sidney Lanier Bridge.
- Farrell’s operating manual required five people on the bridge during the transit: the master, a helmsman, two harbor pilots, and a watch officer (the third mate). Maritime witnesses described that staffing as generally sufficient.
- The watch officer’s assigned role was to remain continuously available to oversee the helmsman’s execution of steering orders; his additional tasks (including keeping a bell log) were described as minor and compatible with that oversight.
- The vessel had a lighted rudder-angle indicator showing rudder position. It was located on the bridge so the helmsman and the watch officer could check it without undue inconvenience.
- As the ship neared the bridge, a pilot ordered the helmsman to put the rudder left 20 degrees. The helmsman repeated the order correctly but moved the rudder 20 degrees to the right instead of to the left.
- Within seconds, the watch officer/third mate detected the error and alerted the bridge team; the pilots and master ordered emergency measures (including hard left rudder and full astern), but the ship struck the bridge.
- The collision caused ten deaths and ten injuries, leading to multiple claims for loss of life, personal injury, and damage.
- Farrell filed a limitation proceeding seeking exoneration from or limitation of liability under 46 U.S.C. § 183; Farrell later conceded it was not entitled to exoneration, leaving only limitation for decision.
- After trial, the district court denied limitation, reasoning that the vessel’s procedures and equipment should have included “fail-safe” precautions and finding deficiencies in bridge staffing, the watch officer’s duties, and placement of the rudder indicator.

## Issues

1. Whether the claimants proved that negligence or unseaworthiness—separate from the helmsman’s steering mistake—contributed to the collision (including alleged deficiencies in bridge staffing, the watch officer’s assigned duties, and rudder-indicator placement).
2. If contributory negligence or unseaworthiness was shown, whether it occurred with the shipowner’s “privity or knowledge” so as to bar limitation under the Limitation of Liability Act, 46 U.S.C. § 183 (including the effect of § 183(e) for death or bodily injury claims).
3. Whether the district court clearly erred by effectively requiring additional “fail-safe” procedures or equipment beyond what reasonable maritime practice demanded.

## Decision

- The Fifth Circuit reversed the district court’s denial of limitation of liability.
- The court held that the district court’s findings of inadequate procedures, personnel, and equipment were clearly erroneous on this record.
- The court concluded that the ship’s bridge complement and the watch officer’s assigned duties were consistent with accepted merchant-marine practice and did not constitute negligent manning or render the vessel unseaworthy.
- The court rejected the view that the rudder-angle indicator’s location caused the casualty or was so poorly placed as to make the vessel unfit for service.
- With the helmsman’s isolated steering mistake agreed to be the predominating cause and not within Farrell’s privity or knowledge, Farrell was entitled to limitation under § 183.
- The case was remanded for further proceedings consistent with limitation (including administration of claims within the limitation fund).

## Legal Principles

- In a limitation action, the court applies a two-step inquiry: (1) identify the acts of negligence or conditions of unseaworthiness that caused the loss, and (2) determine whether the owner had privity or knowledge of those causative acts or conditions.
- The claimants bear the initial burden to prove causative negligence or unseaworthiness; the owner then bears the burden to show lack of privity or knowledge as to the causative negligence or unseaworthiness.
- Privity or knowledge must relate to the negligent act or unseaworthy condition that caused the casualty; awareness of other facts associated with the voyage is not enough to defeat limitation.
- A vessel need not be designed or operated with every possible backup against human error; the relevant standard is reasonable fitness for the service contemplated, measured against accepted maritime practice.
- For death or bodily injury claims, § 183(e) imputes to the owner the master’s privity or knowledge at or before the voyage’s start, but limitation still turns on whether a causative negligent act or unseaworthy condition is shown and is within that imputed privity or knowledge.
- A momentary steering mistake by an otherwise competent crew member, without proof of owner-attributable negligent manning, deficient procedures, or unseaworthy equipment, does not by itself bar limitation.

## Conclusion

The Fifth Circuit held that the *AFRICAN NEPTUNE* was properly staffed and equipped under accepted maritime practice and that the collision with the Sidney Lanier Bridge resulted from an isolated helmsman steering error not within the shipowner’s privity or knowledge; therefore, Farrell Lines was entitled to limitation of liability under 46 U.S.C. § 183.


Farrell Lines, Inc. v. Jones, 530 F.2d 7 (1976)