## Facts

- The dispute arose from maritime tort claims on Alabama’s Black Warrior River, which contains a series of U.S. Army Corps of Engineers lock-and-dam facilities intended to maintain navigational depth rather than control floods.
- On December 2–3, 1983, the river basin experienced extraordinarily heavy rainfall that caused rapid and severe flooding and hazardous river conditions.
- During the flood, a Warrior & Gulf tow pushing barges struck the Highway 82 Bypass Bridge, and barges were lost or damaged.
- Additional Warrior & Gulf tugs responded to assist but also lost barges, leading to a cascading sequence of accidents and property damage affecting multiple companies.
- The claimants alleged that the Corps’ operation of the locks and dams during the storm—especially gate and release decisions at Holt Lock and Dam—caused or worsened river conditions that produced the casualties.
- In consolidated admiralty actions tried on liability only, the district court found the Government’s lock-and-dam operations were the proximate cause of the appellees’ damages and entered liability against the United States.
- The United States appealed, arguing the district court clearly erred on proximate cause because the losses resulted from an act of God. Parker Towing filed a cross-appeal, and some claims between private parties remained unresolved.

## Issues

1. Whether the district court clearly erred in finding that the Corps’ operation of the lock-and-dam system was the proximate cause of the appellees’ damages during the December 2–3, 1983 flood.
2. Whether the unprecedented rainfall and flooding constituted an act of God that superseded any alleged negligence and became the sole proximate cause of the losses.
3. Whether Parker Towing could recover against the United States given the appellate disposition and the posture of remaining claims.

## Decision

- The Eleventh Circuit reversed the district court’s finding of proximate cause and remanded.
- The court held the district court clearly erred in attributing the losses to the Corps’ operational decisions; the unprecedented rainfall and flooding were the proximate cause.
- The court rejected Parker Towing’s effort to obtain recovery against the United States in light of the reversal.
- The case was remanded for further proceedings, including unresolved claims between Parker Towing and Warrior & Gulf.

## Legal Principles

- An act of God—an excessive, unprecedented natural event not reasonably anticipated—can break the causal chain and exonerate a defendant when the event would have produced the damage regardless of alleged negligence.
- Proximate-cause analysis may consider the design purpose and physical capacity of government water-control structures; a navigation project designed to pass inflows is not treated as a flood-control system capable of preventing extraordinary flooding.
- Even under clear-error review, an appellate court may overturn proximate-cause findings when the record shows the natural event’s overwhelming effect renders alleged operational missteps not a substantial factor in producing the harm.

## Conclusion

The Eleventh Circuit held that extraordinary, unprecedented rainfall—not the Corps’ lock-and-dam operations—was the proximate cause of the maritime casualties, reversed the liability judgment against the United States, rejected related recovery efforts premised on that causation finding, and remanded for further proceedings on remaining private-party claims.


Warrior & Gulf Navigation Co. v. United States, 864 F.2d 1550 (11th Cir. 1989)