Collision at sea: The irreconcilability of the superseding cause and pure comparative fault doctrines in admiralty

Courts have long sought to develop rational methods both for limiting a tor tfeasor's liability and allocating damages among multiple tortfeasors. Cour ts developed the doctrine of proximate cause to address the first concern, employing superseding cause analysis when multiple forces produce an injury . In admiralty, the U.S. Supreme Court resolved the second concern by adopt ing pure comparative fault in United States v. Reliable Transfer Co. In Exx on Co. v. Sofec, Inc., the Court endorsed the continued use of superseding cause in admiralty cases, holding that it does not conflict with pure compa rative fault. This Comment argues that the Sofec Court's method of supersed ing cause analysis does indeed conflict with pure comparative fault and sho uld therefore be abandoned. This Comment concludes that superseding cause, regardless of its method of analysis, does not add to the doctrine of proxi mate cause and should be eliminated.