Brooklyn Eastern District Terminal v. United States

In Brooklyn Eastern District Terminal v. United States, 287 U.S. 170 (1932), the United States Supreme Court distinguished the "spare boat" cases. There, a dredge belonging to the United States collided with a tugboat belonging to Brooklyn Eastern. 287 U.S. at 172. The issue in that case was "whether the full-time hire of an extra boat must be charged to the respondent United States as damage flowing from the collision when there was no need of such a boat to keep the business going, and none in fact was used or paid for." Id. at 174. Furthermore, the Supreme Court found that Brooklyn Eastern did not lose any revenue or any enjoyment while the tugboat was being repaired. Id. at 175. The Court also noted that there "has been a refusal to extend the spare boat doctrine to boats acquired and maintained for the general uses of the business." Id. at 177. Looking to English law, in particular a speech by Lord Sumner, the Court held that under the circumstances of the particular case (i.e., no lost revenue and no need for a spare tugboat), Brooklyn Eastern was not entitled to loss-of-use damages. Id. at 177.