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 does not make its expressly specified remedies exclusive, permitting the United States to obtain declaratory relief and recover the costs of removing vessels negligently sunk in navigable waters. It also rejected the asserted right of a negligent owner to abandon a vessel and obtain immunity from personal responsibility, and affirmed further proceedings to determine negligence and recoverable expenses. Justice Harlan, concurring, agreed with the result but emphasized that any injunction compelling removal should be considered under ordinary equitable standards after factual development.
Holding
- Whether the statutory remedies are exclusive. The remedies and procedures specified by the Rivers and Harbors Act for enforcing the prohibition against negligently sinking vessels are not exclusive. The United States may obtain declaratory relief assigning responsibility for rectifying the violation and may recover expenses it incurred in removing a negligently sunk vessel.
- Whether negligent owners may abandon vessels without personal responsibility. The Act does not create an absolute right allowing an owner who negligently sinks a vessel to abandon it and avoid personal civil responsibility. The statutory provisions authorizing government removal and sale protect the United States from liability for its removal operations and establish a lien or related in rem remedies; they do not negate declaratory relief or recovery of removal expenses.
Docket 31
Cited authorities
- 33 U.S.C. §§ 414-415
- 33 U.S.C. § 411.8
- 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