Commonwealth of Puerto Rico v. Marbonanza Compania Naviera S.A., decided Aug. 12, 1980 by the Court of Appeals for the First Circuit

Damages to land in excess of market value allowed against polluting vessel

The decision of the Trial Court awarding $5.5 million damages was reversed as excessive but Judge Campbell said that on remand the Court could go beyond the market value of a tropical mangrove swamp and assess damages based on the total value of the swamp including its effects on the ecosystem.