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Remedies Keyed to Tabb, 8th
Commonwealth of Puerto Rico v. SS Zoe Colocotroni
Citation:
628 F.2d 652 (1981)Facts
On March 18, 1973, the SS Zoe Colocotroni, a tramp oil tanker carrying 187,670 barrels of crude oil from Venezuela to Puerto Rico, became hopelessly lost while navigating by dead reckoning and grounded on a reef three and a half miles off Puerto Rico’s south coast. To refloat the vessel, the captain ordered dumping of more than 5,000 tons of crude oil into surrounding waters. The oil floated westward and came ashore at Bahia Sucia, an isolated peninsula with crescent-shaped bay containing mangrove forests and diverse marine ecosystems. The oil penetrated mangrove forests, coated roots, soaked into sediments, and killed numerous marine organisms. A massive cleanup operation recovered approximately half the spilled oil, but substantial contamination remained in the West Mangrove area four years later, continuing to harm the ecosystem’s capacity to support marine life.
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