## Facts

- On a clear but windy night in December 1968, the coastal tanker *Mary A. Whalen*, owned by Reliable Transfer Co., traveled from New Jersey toward New York, crossing near Rockaway Inlet.
- A breakwater near the route was normally marked by a flashing light maintained by the U.S. Coast Guard, but the light was not operating that night.
- As the tanker approached Rockaway Point, its captain attempted maneuvers to pass a tug and barge, including a 180-degree turn, and the tanker stranded on a sandbar.
- Reliable Transfer sued the United States, alleging Coast Guard negligence in failing to maintain the flashing light.
- The district court found the tanker 75% at fault and the Coast Guard 25% at fault, but applied the admiralty divided-damages rule and split the tanker’s property damage equally.
- The court of appeals affirmed.

## Issues

1. In maritime collision or stranding cases where multiple parties are at fault, must property-damage liability be allocated in proportion to comparative fault rather than divided equally under the traditional divided-damages rule?
2. If comparative fault allocation is required, when, if ever, is equal allocation still permitted?

## Decision

- The Supreme Court vacated the judgment and remanded.
- The Court abolished the divided-damages rule for maritime collision and stranding property-damage cases involving mutual fault.
- The Court held that damages must be allocated proportionately to the parties’ comparative degrees of fault when such apportionment can fairly be made.
- Equal allocation is permitted only if the parties are equally at fault or if comparative fault cannot fairly be measured.
- The case was returned for further proceedings consistent with comparative-fault allocation (rather than a mandatory 50/50 split).

## Legal Principles

- In maritime collision or stranding cases causing property damage, when two or more parties contribute by fault, liability must be allocated proportionately to comparative fault when feasible.
- Equal division of damages is not the default rule; it applies only when fault is equal or cannot be fairly compared.
- A longstanding admiralty doctrine created by judicial decision may be revised by the Court when it produces unjust results and is not mandated by statute.

## Conclusion

The Court replaced admiralty’s automatic equal division of property damages in mutual-fault collision and stranding cases with a comparative-fault rule, allowing equal allocation only when fault is equal or cannot be fairly apportioned.


United States v. Reliable Transfer Co., 421 U.S. 397 (1975)