Crowley Marine Services Inc. v. Maritrans Inc.

This case calls on us to decide a matter of first impression regarding the application of the International Regulations for Preventing Collisions at Sea, Oct. 20, 1972, 28 U.S.T. 3459, T.I.A.S. 8587, adopted by statute at 33 U.S.C. § 1602 , better known by their common acronym as the COL-REGS. Crowley Marine Services, Inc. (“Crowley”) 'owned and operated a tug boat hired to accompany an oil tanker operated by Maritrans Operating Company L.P. (“Maritrans”) to an oil platform in the Puget Sound. During the crossing the two vessels collided, causing more than $2 million in damages.

In the inevitable suit that followed, each side identified numerous violations of the COLREGS as the alleged cause of the collision. The district court apportioned fault for the accident as 75% to Crowley and 25% to Maritrans. The district court found that the two vessels were operating in concert according to agreed maneuvers, and therefore determined that several substantive provisions of the COLREGS at issue were inapplicable. Specifically, the court ruled that this situation presented “special circumstances” that provide an exception to the COLREGS. We hold that the plain language of the COLREGS…