The United States Court of Appeals for the Second Circuit has recognized a quasi-contract remedy for those who save life on the high seas. The Note examines the court's decision in light of admiralty's traditional stance denying recovery to the life salvor and legislative responses to that doctrine.
Derek B. Jacobson,
Restitution for Life Salvage at Sea in the Wake of Peninsular & Oriental Steam Navigation Co. v. Overseas Oil Carriers, Inc.,
30 Hastings L.J. 227
Available at: https://repository.uchastings.edu/hastings_law_journal/vol30/iss1/7