Penny Barnett v. United States
23-2221
4th Cir.Mar 19, 2025Background
- Edward Barnett died in a nighttime boat crash after his vessel struck a dike in the Cooper River, South Carolina, while heading back from a job site.
- The dike was identified by several navigational aids, including amber and green lights, but one amber light closest to shore was inoperable at the time.
- Barnett's widow sued the U.S. Coast Guard under the Suits in Admiralty Act (SIAA), claiming negligence in maintaining or improving the navigation aids.
- The district court found for the government, applying the discretionary function exception to most claims and finding Barnett's actions were the proximate cause of the accident.
- The appeal focused on whether the Coast Guard breached any duty and whether the discretionary function exception applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discretionary Function Exception Under SIAA | Coast Guard duties regarding light maintenance/improvement are non-discretionary | Coast Guard has broad discretion; regulations do not mandate specific action | Exception applies—regulations are discretionary, bar most claims |
| Duty to Maintain Navigational Aids | Duty required aids to be adequately visible and timely repaired | Duty is only to repair aids, not to upgrade or improve beyond 'working order' | Duty is to repair and not mislead; no duty to update/upgrade aids |
| Breach of Duty for Inoperable Amber Light | Inoperable light meant lighting did not adequately warn of the dike | Remaining lights were functioning and not misleading | No breach; failure of one light did not mislead or induce reliance |
| Proximate Cause of Accident | Coast Guard's inadequate aids caused/were a factor in the crash | Barnett's actions alone caused the accident | Barnett's negligence was the sole proximate cause |
Key Cases Cited
- Indian Towing Co. v. United States, 350 U.S. 61 (Coast Guard duty arises after installing/undertaking maintenance of navigational aids; must not mislead mariners)
- Faust v. S.C. State Highway Dep’t, 721 F.2d 934 (Coast Guard’s duty limited to not misleading by navigational aids)
- Magno v. Corros, 630 F.2d 224 (No liability for failing to provide additional lighting if existing lights are maintained and not misleading)
- Ente Nazionale per L’Energia Elettrica v. Baliwag Nav., Inc., 774 F.2d 648 (Proximate cause in admiralty defined as the direct, unbroken sequence leading to injury)
- McMellon v. United States, 387 F.3d 329 (Scope of SIAA discretionary function exception; mirrors FTCA)