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Article: Recent developments in admiralty law in the United States Supreme Court, the Fifth Circuit, and the Eleventh Circuit.(U.S. 5th and 11th Circuit Courts of Appeal)
- Article from:
- Houston Journal of International Law
- Article date:
- March 22, 1999
- Author:
CopyrightCOPYRIGHT 1999 Houston Journal of International Law. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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I. INTRODUCTION
The Supreme Court decided two maritime cases during the 1997-1998 term. In the case of California v. Deep Sea Research, Inc.,(1) the Court clarified, and slightly narrowed, the states' Eleventh Amendment immunity from suits in rem,(2) sixteen years after Treasure Salvors(3) announced that immunity.(4) The Supreme Court's decision in Dooley v. Korean Air Lines Co.,(5) a Death on the High Seas Act (DOHSA)(6) case, is more generally applicable. In Dooley, the Court standardized the law of maritime death cases, holding that there can be no action under general law for something that is disallowed under DOHSA.(7) The opinion serves as an interesting ...