## Facts

- Halcyon Lines owned a vessel moored in navigable waters and hired Haenn Ship Ceiling & Refitting Corp. to perform ship repairs.
- Salvador Baccile, a Haenn employee, was injured aboard the ship while performing the repair work.
- Baccile sued Halcyon in federal district court, alleging negligence and unseaworthiness.
- Halcyon impleaded Haenn, alleging Haenn’s negligence contributed to the injury and seeking contribution.
- The parties agreed to a $65,000 judgment for Baccile, which Halcyon paid.
- Over Haenn’s objection, the jury returned a special verdict allocating fault 75% to Haenn and 25% to Halcyon.
- The district court rejected the jury allocation and entered judgment on a 50/50 split based on a supposed general maritime rule of equal division among joint tortfeasors.
- The court of appeals recognized contribution but limited Haenn’s exposure to the amount it would owe under the applicable workers’ compensation scheme.

## Issues

1. Whether federal maritime law recognizes a right of contribution between joint tortfeasors in a non-collision maritime personal-injury case.
2. Whether a shipowner that pays an injured contractor-employee may obtain contribution from the contractor-employer whose liability to the employee is limited by workers’ compensation.

## Decision

- The Supreme Court reversed and remanded with directions that the contribution proceedings against Haenn be dismissed.
- The Court held there was no established maritime right of contribution between joint tortfeasors in non-collision personal-injury cases.
- The Court declined to create such a right in light of extensive congressional legislation governing maritime injuries that did not provide for contribution in this setting.

## Legal Principles

- The admiralty “divided damages” rule developed for vessel collision cases does not supply a general contribution rule for non-collision maritime torts.
- Absent an established maritime doctrine or statutory authorization, a shipowner has no federal maritime right to obtain contribution from a contractor-employer for an employee’s injury in a non-collision personal-injury action.
- Where Congress has legislated broadly in maritime injury compensation and liability but has not created a contribution remedy, courts should not add one that would alter the statutory allocation of liability.

## Conclusion

The Court refused to extend maritime law to permit contribution between non-collision joint tortfeasors when the third-party employer’s liability to its employee is confined by workers’ compensation, leaving any change in that allocation to Congress.


Halcyon Lines v. Haenn Ship Ceiling & Refitting Corp., 342 U.S. 282 (1952)