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Emphasizing the extent of equity discretion available to admiralty courts, the Court of Appeals for the Third Circuit ruled that maintenance and cure expenses resulting from a seaman's "recurring" injury should be borne equally by the obligor liable for the original injury and the owner in whose employ the injury was heightened. However, where the injury has resulted .from the violation of a duty owed the seaman by either obligor, the total liability is the responsibility of the offending party. Although determining the extent of contribution in an inequitable albeit facile manner, the decision bars arbitrary imposition of liability and significantly indicates judicial disfavor of the traditional impediments to loss distribution in maritime law.

Admiralty: Rights of Contribution and Exoneration Established between Coextensive Maintenance and Cure Obligors