George M. Earle

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Survey Article


The Eleventh Circuit Court of Appeals published six admiralty opinions in 1999. The court faced one issue of first impression, but otherwise applied existing case law to decide the cases before it. In the case presenting the issue of first impression, the court joined the Fifth Circuit in holding that an ocean carrier's unreasonable deviation does not nullify the one-year statute of limitation for filing suit under the Carriage of Goods by Sea Act. The cases decided with reference to existing law included two cases involving maritime liens, one case addressing appellate jurisdiction, one case addressing personal jurisdiction, and one case resolving whether one party's alleged nonperformance under a contract of carriage would excuse the other party's performance.

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