Reserve Mooring, Inc. v. American commercial Barge Line, L.L.C.,

While moored at a mooring facility owned by the plaintiff, the defendant’s barge sank. Although the accident did not cause physical damage to the mooring facility, the site remained blocked until salvage operations were completed. The plaintiff sought to recover lost income resulting from the loss of use of the mooring site allegedly due to the defendant’s negligence. Relying on the Robins Dry Dock rule, the Court of Appeals held that physical injury to a proprietary interest is a prerequisite to recovery of economic damages in unintentional maritime torts. Therefore, the owner of the mooring facility was not entitled to recover any damages for loss of use.