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Commonwealth of Puerto Rico v. SS Zoe Colocotroni

United States Court of Appeals for the First Circuit
628 F.2d 652 (1981)


In 1973, the SS Zoe Colocotroni (ship) (defendant), a tramp-oil tanker, became lost and grounded on a reef. In an attempt to free the ship, the ship’s captain emptied the cargo of crude oil into the sea. The oil floated westward into Bahia Sucia, a bay off of Puerto Rico. The oil entered the bay, the beaches, and the mangrove forests near the bay. The United States Coast Guard and several agencies of the Commonwealth of Puerto Rico (Commonwealth) (plaintiff) began a cleanup operation. Subsequently, the Commonwealth and the local Environmental Quality Board (EQB) (plaintiff) brought suit against the ship and its owners (defendants) to recover damages for harm done to the coastal environment by the oil. After trial, during which various experts testified, the federal district court awarded damages to the plaintiffs based on the replacement cost of the approximately 92,109,720 marine animals killed by the oil spill. The plaintiffs had expressly stated at trial that they did not intend to replace all the animals, but rather were suggesting this value as an approximation. The defendants appealed, arguing that the correct standard was the diminution of value after the oil spill, and that damages therefore could not exceed $5,000 per affected acre because the market value of the land was no more than $5,000 per acre.

Rule of Law


Holding and Reasoning (Campbell, J.)

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