Buffalo Marine Services Inc. v. United States
663 F.3d 750
| 5th Cir. | 2011Background
- Oil spill on the Neches River from Buffalo Marine’s barge colliding with the TORM MARY; ~27,000 gallons of heavy fuel oil released.
- NPFC denied a joint claim for cleanup-cost reimbursement under the Oil Pollution Act (OPA) and no direct contract between Torm and Buffalo Marine.
- Claimants sought to substitute Buffalo Marine as the responsible party and to cap Buffalo Marine’s liability under the OPA; TORM argued third-party defense under § 2703(a)(3).
- District court granted summary judgment for the government; appellants appealed the NPFC decision.
- Court analyzes whether NPFC’s interpretation of § 2703(a)(3) defers to agency construction and whether the denial was supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NPFC's § 2703(a)(3) interpretation warrants deference. | Buffalo Marine argues narrower, direct-contract reading. | NPFC adopts broad, indirect-contract interpretation. | NPFC interpretation entitled to deference. |
| Whether the third-party defense applies where acts occur within an indirect contractual relationship. | Inapplicable if no direct contract; relies on direct privity. | Any contractual relationship, direct or indirect, fits the defense. | Defense fails because acts tied to a contractual relationship; no sole third-party act outside such connection. |
| Whether NPFC’s denial was supported by substantial evidence and not arbitrary. | Evidence shows no link to a contractual relationship. | Evidence shows acts connected to bunkering contract chain. | denial upheld; adequate evidence supports connection to contractual relationship. |
Key Cases Cited
- Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (U.S. 1984) (establishes two-step framework for deference to agency interpretations)
- Tex. Clinical Labs, Inc. v. Sebelius, 612 F.3d 771 (5th Cir. 2010) (affirms deferential review of agency interpretations under APA)
- United States v. LeBeouf Bros. Towing Co., 621 F.2d 787 (5th Cir. 1980) (narrow interpretation of third-party defense to preserve strict liability)
- Mocklin v. Orleans Levee Dist., 877 F.2d 427 (5th Cir. 1989) (interprets scope of 'any contractual relationship' in damages contexts)
- Crandon v. United States, 494 U.S. 152 (U.S. 1990) (statutory interpretation and broad readings in defense provisions)