443 U.S. 256, 99 S. Ct. 2753, 61 L. Ed. 2d 521, 1979 AMC 1167 (1979)
On March 3, 1974, the S.S. Atlantic Cognac, a container ship owned by respondent Compagnie Generale Transatlantique, arrived at the Portsmouth Marine Terminal in Virginia.1 Petitioner Stanley Edmonds, a longshoreman employed by Nacirema Operating Co., was assigned to unload cargo from the vessel as part of the stevedoring work the shipowner had contracted with Nacirema to perform.2
Edmonds sustained injuries while carrying out that work.3 He received statutory compensation benefits from his employer under the Longshoremen's and Harbor Workers' Compensation Act.4 He also commenced a negligence action against the shipowner in federal district court.5
A jury determined that Edmonds had incurred total damages of $100,000, that he bore 10 percent of the responsibility for his injury, that the stevedore employer through a co-employee's negligence accounted for 70 percent of the total fault, and that the shipowner was responsible for the remaining 20 percent.6 The district court reduced the award by the 10 percent share attributed to Edmonds's own negligence.7
The United States Court of Appeals for the Fourth Circuit, sitting en banc with two judges dissenting, reversed the district court's judgment.8 The Supreme Court granted certiorari to resolve the conflict that had developed among the circuits on the proper application of the 1972 Amendments.9
Additional facts developed at trial showed that a member of the ship's crew had directed Edmonds to remove a jack from the rear wheel of a large cargo container.10 Another longshoreman then backed a truck into the container, causing it to roll backward and pin Edmonds against the bulkhead.11
Whether the 1972 Amendments to the Longshoremen's and Harbor Workers' Compensation Act altered the traditional admiralty rule under which a shipowner remains liable for the full amount of an injured longshoreman's damages despite concurrent negligence by the stevedore employer?12
The traditional admiralty rule, consistent with common law, holds that a tortfeasor is liable for the full amount of damages for an indivisible injury even if other concurrent tortfeasors contributed, and the 1972 Amendments did not change this rule with respect to the shipowner's liability to the longshoreman.13
No. The amendments eliminated the unseaworthiness action and the Ryan indemnity but preserved the longshoreman's right to recover full damages from a negligent shipowner.14 On March 3, 1974, the S.S. Atlantic Cognac arrived at the Portsmouth Marine Terminal where petitioner Stanley Edmonds, employed by Nacirema Operating Co., was injured while unloading cargo.15 A jury determined total damages of $100,000 with Edmonds responsible for 10 percent, the stevedore for 70 percent through a co-employee, and the shipowner for 20 percent.16 The district court reduced the award only by Edmonds's share, and the Supreme Court held that the statute does not require further apportionment based on the stevedore's fault.17
The 1972 Amendments did not alter the traditional admiralty rule of full liability for the shipowner.18
Related opinions on this issue
Joined by Justices Marshall And Stevens
Justice Blackmun dissented, arguing that the Court should adopt a comparative negligence rule.19 He noted that the jury found the shipowner 20 percent responsible, the stevedore 70 percent, and the longshoreman 10 percent.20 Under the majority's holding, the shipowner pays 90 percent while the stevedore recoups its benefits.21
Blackmun contended that Congress did not intend to prohibit the Court from fashioning a comparative negligence rule.22 He argued that such a rule would be fairer.23 It would ensure the longshoreman receives statutory benefits for the portion not attributable to the shipowner.24
Whether the Supreme Court should itself modify the traditional maritime rule to limit a shipowner's liability in a longshoreman's negligence action to the percentage of damages attributable to the shipowner's own fault?25
Although admiralty law is largely judge-made, once Congress has relied on existing rules in amending the statute, the Court should not alter those rules to reach different results than Congress envisioned.26
No. The Court has previously acknowledged arguments for comparative fault but recognizes that changing the rule here would upset the delicate balance Congress struck in the 1972 Amendments between stevedores, shipowners, and longshoremen.27 The facts of this case, with the shipowner's 20 percent fault leading to full liability after plaintiff's reduction, illustrate the operation of the preserved rule.28 Edmonds received statutory benefits from his employer under the Longshoremen's and Harbor Workers' Compensation Act.29 He pursued the negligence action against the shipowner.30
The Supreme Court should not modify the traditional maritime rule.31
Related opinions on this issue
Joined by Justices Marshall And Stevens
Justice Blackmun dissented on this point as well.32 He maintained that no statutory or judicial precept precludes a change in the rule.33 A proportional fault rule would bring recovery into line with the rule of admiralty law long since established as between the longshoreman and the shipowner.34
He emphasized that the legislative history shows Congress intended to preserve the role of the federal courts in filling in the contours of section 905(b) in accordance with admiralty tradition.35