Commonwealth of Puerto Rico v. SS Zoe Colocotroni

An oil tanker (defendant) grounded on a reef and, in trying to free itself, spilled crude oil that devastated a Puerto Rican bay's beaches and mangrove forests; the Commonwealth and its environmental agency (plaintiffs) sued for environmental damages, and the district court, based on expert testimony, awarded damages calculated as the theoretical replacement cost of roughly 92 million killed marine animals — even though the plaintiffs themselves admitted they had no actual intention of replacing all those animals and offered the figure merely as an approximation. The defendants appealed, arguing the correct measure was instead the land's diminished market value, which they claimed capped damages at a much smaller amount.