DISCLAIMER: Each year, the Tulane Maritime Law Journal receives more quality comments and case notes from its Junior Members than it can publish in print.  In order to recognize the time and effort expended by our Junior Members whose work is not selected for print publication, we have decided to publish select case notes for online publication.  As a matter of disclaimer, these works have not had the same rigid level of editing that our print works undergo.  However, each online case note, such as this one, has been through an abridged version of our print editing process.  Professor Robert Force, one of the Journal’s Faculty Advisors, has reviewed it.