## Facts

- United Continental Tuna Corp., a Philippine corporation, owned and operated the fishing vessel M/V Orient.
- The Orient collided with the U.S.S. Parsons, a United States naval destroyer, and the Orient sank, allegedly causing substantial damages.
- United Continental sued the United States in admiralty in the Central District of California, invoking both the Suits in Admiralty Act (SIAA) and the Public Vessels Act (PVA).
- The PVA governs suits for damages caused by “a public vessel of the United States” and includes a reciprocity condition for suits by foreign nationals or entities.
- In 1960, Congress amended the SIAA by deleting language limiting coverage to government vessels “employed as a merchant vessel,” creating overlap questions between the SIAA and PVA.

## Issues

1. Whether the 1960 amendment to the SIAA permits claims involving a public vessel to be brought under the SIAA to avoid the PVA’s limitations, including the reciprocity requirement.
2. Whether claims that fall within the PVA’s scope remain governed by the PVA’s terms after the 1960 expansion of the SIAA.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- The Court held that claims within the scope of the PVA remain subject to the PVA’s terms after the 1960 SIAA amendment.
- Because the U.S.S. Parsons was a public vessel, the respondent’s claim fell within the PVA, and the PVA’s reciprocity requirement applied.

## Legal Principles

- When a maritime claim is within the PVA’s coverage, the PVA is the controlling waiver of sovereign immunity and its conditions apply.
- The 1960 amendment to the SIAA did not impliedly repeal, override, or nullify the PVA’s specific restrictions on suits involving public vessels.
- A plaintiff may not circumvent the PVA’s statutory limitations by pleading the action under the SIAA when the claim is substantively one for damage caused by a U.S. public vessel.
- Repeals by implication are disfavored; courts require clear congressional intent before treating a later, more general statute as displacing a prior, more specific statutory regime.

## Conclusion

The Court held that the Public Vessels Act continues to govern suits for damages caused by U.S. public vessels, and that foreign plaintiffs cannot rely on the expanded Suits in Admiralty Act to avoid the PVA’s reciprocity condition.


United States v. United Continental Tuna Corp., 425 U.S. 164 (1976)