(1) in 1999, it weighed state and federal statutory law against the common law of admiralty
to decide that Alaska municipalities could sustain a claim against Exxon for the cost of services diverted from their citizens in order to participate in the environmental cleanup effort necessitated by the Exxon Valdez oil spill.
825 (1999) ("[T]he Constitution conferred admiralty subject matter jurisdiction on federal courts and, by implication, authorized the federal courts to draw upon and to continue the development of the substantive, common law of admiralty
when exercising admiralty jurisdiction."); Cobb Coin Co.
Ray McDermott & Co.(9) that an award of punitive damages under the general maritime law may be obtained when an employer willfully and callously refuses to pay maintenance and cure to an injured seaman.(10) However, upon rehearing Guevara, the court noted that significant developments in the law of admiralty
since the Holmes decision required a rethinking of its position.(11)
Black, Jr., The Law Of Admiralty
526 (1957) (calling Jensen "the most ill-advised admiralty decision ever handed down by the Supreme Court").