Supreme Court of the United States
Wyandotte Transportation Co. v. United States
December 4, 1967389 U.S. 191
Summary
The Court held that the Rivers and Harbors Act of 1899 does not make its listed remedies exclusive and therefore permits the United States to obtain declaratory relief and recover removal expenses from parties whose negligence caused a vessel to sink in navigable waters. It also rejected the argument that the Act gives negligent owners an absolute right to abandon sunken vessels without personal civil responsibility. The Court affirmed the reversal of summary judgments and remanded for proceedings to determine negligence and related issues. Justice Harlan, concurring, agreed with the result but would leave any request for an injunction compelling removal to ordinary equitable standards after factual development.
Holding
- Exclusivity of statutory remedies. The remedies and procedures specified by the Rivers and Harbors Act of 1899 for enforcing the prohibition on negligent sinking were not intended to be exclusive. The United States may obtain declaratory relief and recover expenses incurred in removing a vessel negligently sunk in navigable waters.
- Abandonment and personal civil responsibility. The Act does not grant an absolute right to abandon a negligently sunk vessel and thereby obtain immunity from personal civil responsibility for removal or related consequences.
Docket 31
Cited authorities
- 33 U.S.C. §§ 414-415
- 30 Stat. 1151
- 33 U.S.C. § 401
- 64 Stat. 1109
- 42 U.S.C. §§ 1855
- 33 U.S.C. § 409
- 33 U.S.C. § 409
- 33 U.S.C. §§ 414-415
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