Saratoga Fishing Company v. J. M. Martinac & Company

PETITIONER: Saratoga Fishing Company
RESPONDENT: J. M. Martinac & Company
LOCATION: Senator Byrd's Office

DOCKET NO.: 95-1764
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 520 US 875 (1997)
ARGUED: Feb 18, 1997
DECIDED: Jun 02, 1997

ADVOCATES:
Daniel B. MacLeod - Argued the cause for the respondents
Keith Zakarin - Argued the cause for the petitioner

Facts of the case

J. M. Martinac & Co. built the fishing vessel M/V Saratoga. Martinac installed a hydraulic system designed by Marco Seattle Inc. in the Saratoga. The initial user, Joseph Madruga, bought the ship new and added extra equipment. Madruga then sold the Saratoga to Saratoga Fishing Co., the subsequent user. Saratoga Fishing used the ship until it caught fire and sank. Saratoga Fishing then filed an admiralty tort suit against Martinac and Marco. Precedent stated that an admiralty tort plaintiff cannot recover damages for the physical damage that a defective product caused to the "product itself," but can recover damages for physical damage that the product caused to "other property." The District Court found that the hydraulic system had been defectively designed and awarded Saratoga Fishing damages, including damages for the loss of the equipment added by Madruga. The Court of Appeals reversed. It held that the added equipment was part of the ship when it was resold to Saratoga Fishing and, therefore, was part of the defective product that itself caused the harm.

Question

Can extra equipment, added to a ship after it was constructed, be considered "other property" for which the ship manufacturer is liable?

Media for Saratoga Fishing Company v. J. M. Martinac & Company

Audio Transcription for Oral Argument - February 18, 1997 in Saratoga Fishing Company v. J. M. Martinac & Company

Audio Transcription for Opinion Announcement - June 02, 1997 in Saratoga Fishing Company v. J. M. Martinac & Company

The opinion of the Court in Number 95-1765, Saratoga Fishing Company versus J.M. Martinac & Company will be announced by Justice Breyer.

This case involves a tuna fishing ship called the Saratoga, which caught fire and sank in 1986.

A defective hydraulic system caused the loss.

The legal question is a narrow one.

It's in a little corner of admiralty, tort law.

Can the ship's owners recover in tort for a skiff and sand nets that were attached to the ship?

Now, the reason that the question is complicated legally is the following, a component maker, the person who made the hydraulic system, delivered it to a manufacturer, who made the ship, who then sold it to a first user, who added the skiff and the nets and who then resold it to the current user.

Now, everybody agrees that if the manufacturer had been the one to add the skiff and the nets, the owners would not be able to recover in tort.

That's because a special tort doctrine leaves a buyer of a defective product that -- imagined, it exploded, it would leave that buyer to a contract remedy to recover the value of the product that exploded itself, though he could recover in tort for the value of other property that the exploding product harmed.

Now, everybody also agrees that if the ship had sunk before the first user, who added the skiff and the net, had resold the product, the first user could recover in tort.

That's because since the skiff and the net were added by the first user, they quite clearly, were not part of the defective product itself.

They would have been other property.

Now, what happens if the first user, who added the skiff and the nets, sold the ship with the skiff and the nets added to a subsequent user?You could consider the skiff and the nets to be part of the defective product itself because from the second user's point of view, they are part of the product that he bought.

On the other hand, you also can consider them to be other property, for that is what they were in the hands of the first user.

We resolve this legal conundrum in favor of characterizing them even in the subsequent user's hands as other property, which will permit the subsequent user and the present owner to recover their value in tort.

We set out our reasons in the opinion.

Justice O'Connor has filed a dissenting opinion, as has Justice Scalia joined by Justice Thomas.