Among the reasons this is worth reading (even if you don’t care about admiralty):

1.  Moragne goes into the history of wrongful death and explains why the common law did not provide a remedy.  The answer is that the “felony-merger” doctrine in England held that all property owned by a [...]]]> This week in my Admiralty class I taught my favorite case–Moragne v. States Marine Lines, Inc., 398 U.S. 375 (1970). This unanimous opinion, written by Justice John Marshall Harlan, held that a wrongful death action existed in general maritime law. Moragne overruled The Harrisburg, an 1886 case that followed the common law and said that there was no wrongful death remedy in admiralty. Many scholars believe that this is the best Supreme Court opinion, if by best you mean”most professional.”

Among the reasons this is worth reading (even if you don’t care about admiralty):

1.  Moragne goes into the history of wrongful death and explains why the common law did not provide a remedy.  The answer is that the “felony-merger” doctrine in England held that all property owned by a convicted murderer went to the Crown.  Thus, there could be no recovery by a private party.  Even though no such doctrine existed here, our courts blindly adopted the English rule.

2.  The Court grounds its decision to overrule its precedent by doing an exhaustive review of the erosion of the “no wrongful death” rule, by looking at state statutes, Acts of Congress, international law, and academic criticism.

3.  The Court explains why Congress’s decision to create a wrongful death remedy in international waters (in the Death on the High Seas Act) does not preclude the creation of a judicial equivalent in territorial waters where state law does not do so.  That part of the opinion involves a thoughtful discussion of federalism, statutory interpretation, and the evolution of the admiralty remedy of unseaworthiness (which I’ll talk more about next week).

4.  The Court then concludes by offering a detailed explanation about why stare decisis does not counsel in favor of sticking with precedent in this instance, largely because the current rules promotes uncertainty and leads to all sorts of inconsistent outcomes in similarly situated cases.

Take a look sometime–you’ll be glad you did.

Large ships that enter a harbor or a major river generally must be steered by a pilot.  A pilot is a local person who knows where all of the sandbars, rocks, and channels are in a particular locale.  The captain of the vessel lacks this knowledge and would founder or crash without a pilot in command. Louisiana had a law providing that a new pilot could only be licensed if a current pilot took him on [...]]]> I am in the process of revising my admiralty syllabus, and one case that I’m going to teach next year is Kotch v. Board of River Boat Pilots Com’rs for the Port of New Orleans 330 U.S. 552 (1947).  It’s a fascinating case and I thought I’d give you a summary.

Large ships that enter a harbor or a major river generally must be steered by a pilot.  A pilot is a local person who knows where all of the sandbars, rocks, and channels are in a particular locale.  The captain of the vessel lacks this knowledge and would founder or crash without a pilot in command. Louisiana had a law providing that a new pilot could only be licensed if a current pilot took him on as an apprentice.  Some people who were denied an apprenticeship sued claiming that the pilots in the state were only hiring their relatives and friends.  This kind of cronyism, it was alleged, violated the Equal Protection Clause.

The Supreme Court, in a 5-4 vote, rejected this claim.  Justice Hugo Black wrote for the majority and said that there was a rational basis for allowing pilots broad discretion to select their apprentices because “[a] pilot does not require a formalized technical education so much as a detailed and extremely intimate, almost intuitive, knowledge of the weather, waterways and conformation of the harbor or river which he serves.”  As a result, “the advantages of early experience under friendly supervision in the locality of the pilot’s training, the benefits to morale and esprit de corps which family and neighborly tradition might contribute, the close association in which pilots must work and live in their pilot communities and on the water, and the discipline and regulation which is imposed to assure the State competent pilot service after appointment, might have prompted the legislature to permit Louisiana pilot officers to select those which whom they would serve.”

Justice Rutledge dissented and said that “[i]f Louisiana were to provide by statute in haec verba that only members of John Smith’s family would be eligible for the public calling of pilot, I have no doubt that the statute on its face would infringe the Fourteenth Amendment.” The Court’s decision approves “as constitutional state regulation [a statute] which makes admission to the ranks of pilots turn finally on consanguinity. Blood is, in effect, made the crux of selection.”

This is one of the few Supreme Court cases that directly addresses the legality of nepotism, and I think that it deserves further study.

1.  When I taught Admiralty last semester, I pointed out to my students that many of the statutes in this area are obsolete.  But, I quickly added, Congress won’t do anything about this until there’s a crisis.  Now we see a slew of proposals to amend the Jones Act, amend the Death on the High Seas Act, amend the Limitation of Liability Act, and overturn the Court’s decision on punitive damages in the Exxon Valdez case.  Maritime law is hot!  Of course, whether this sort of knee-jerk response leads to thoughtful changes is another matter, but overall it’s probably better that these neglected topics just get attention.

2. [...]]]> In anticipation of the President’s speech tonight, I thought I’d make some observations about the situation in the Gulf.

1.  When I taught Admiralty last semester, I pointed out to my students that many of the statutes in this area are obsolete.  But, I quickly added, Congress won’t do anything about this until there’s a crisis.  Now we see a slew of proposals to amend the Jones Act, amend the Death on the High Seas Act, amend the Limitation of Liability Act, and overturn the Court’s decision on punitive damages in the Exxon Valdez case.  Maritime law is hot!  Of course, whether this sort of knee-jerk response leads to thoughtful changes is another matter, but overall it’s probably better that these neglected topics just get attention.

2.  The discussion about setting up a 9/11 style Fund (paid for by BP) to address claims arising from the disaster is intriguing.  It seems to me, though, that some new statute will required to make this work.  In particular, I’m not clear on how such a fund would interact with bankruptcy law.  Suppose BP puts $10 billion in escrow for the fund.  Then later they have to file for Chapter 11.  I don’t think that the fund would be immune from other creditors or that litigants would have priority over them (admittedly, though, some of my co-bloggers know far more about this than I do).

3.  A far less important point.  This crisis shows why the AALS Annual Meeting should not require such an early date for setting up panels.  Obviously, I’d like to do this year’s Admiralty Section panel on the spill.  But now I can’t — the deadline for setting up the panel was two months ago.  Granted, AALS can organize a separate one on the issue, but their rigidity with respect to the sections is rather irritating.

Perhaps some future [...]]]> As the Gulf disaster continues, it is worth thinking about about the potential liability of BP and other parties.  Following the Exxon Valdez disaster, the Supreme Court held, acting in its capacity as a common-law court, that punitive damages in admiralty could not exceed the compensatory damage award.  Justice Breyer dissented from this part of the opinion, explaining that “this was no mine-run case of reckless behavior. The jury could reasonably have believed that Exxon knowingly allowed a relapsed alcoholic repeatedly to pilot a vessel filled with millions of gallons of oil through waters that provided the livelihood for the many plaintiffs in this case. Given that conduct, it was only a matter of time before a crash and spill like this occurred.”

Perhaps some future court will distinguish Exxon from a suit against BP, but the opinion is awfully clear that a 1:1 rule is the law.  Congress, though, is free to change this, since Exxon is not part of the Court’s due process jurisprudence on punitive damages (which treats anything above 10:1 as suspect). Just as Congress may amend the Limitation of Liability Act in response to this crisis, they should also look at the punitive damage question.

I am very skeptical that the statute applies to an offshore oil platform, in part because that is not [...]]]> Transocean (RIG), which owns the platform that exploded in the Gulf and caused the massive ongoing oil spill, is seeking to invoke the Limitation of Liability Act of 1851. This law, which has never been amended with respect to property or environmental damage claims, provides that a carrier cannot be held liable for anything more than the value of the vessel and its contents if the ship is involved in an accident that causes those sorts of harms.  It probably goes without saying that the value of the oil platform (more specifically, what’s left of it) is way less than RIG’s probable share of the cleanup costs.

I am very skeptical that the statute applies to an offshore oil platform, in part because that is not navigable and does not involve “traditional maritime activity.”  More broadly, though, this might be the right time to abolish this doctrine entirely.  Maritime scholars (me included) have long held that in a modern world of insurance and corporate organization, the limitation of liability is obsolete.  The problem is that Congress hasn’t had any reason to repeal the 1851 Act — it’s a pretty obscure area of law.  A high-profile incident like the Gulf spill, though, might change that, especially if a court somewhere accepts RIG’s defense.

The most fruitful analogy for thinking about this problem comes from piracy.  (Eugene Kontorovich has an excellent paper on the modern aspects of this comparison coming out in California Law Review.)  Pirates and terrorists are both irregular enemies (or unlawful combatants) whose actions are clearly condemned by international law.  So I thought I would talk about [...]]]> Officials in Washington are still struggling with how to deal with the alleged terrorists detained in Guantanamo.  One day the issue is whether some of them should be tried in a civilian court and, if so, where?  Another day the question is whether, and how, they should be tried by military commissions.  And then there is the thought that some of the detainees should just be held indefinitely without trial.

The most fruitful analogy for thinking about this problem comes from piracy.  (Eugene Kontorovich has an excellent paper on the modern aspects of this comparison coming out in California Law Review.)  Pirates and terrorists are both irregular enemies (or unlawful combatants) whose actions are clearly condemned by international law.  So I thought I would talk about the British experience with suppressing piracy to see what we might learn about dealing with alleged terrorists.

If you look at British practice (and I’m drawing here from Nick Leeson’s excellent book), you’ll see that they faced the same basic problem that we are dealing with — how do you prove in an ordinary trial that someone is a pirate?  The first British statutes (in the 14th century) provided that pirates be tried in an Admiralty court (without a jury) and that either a confession or the testimony of two eyewitnesses were necessary to obtain a conviction.  That eventually proved unworkable, so in 1536 Parliament passed the Offenses at Sea Act, which shifted pirate trials to common law courts (with a jury) and allowed a broader range of evidence to be introduced.  The problem here, though, was that this statute required the trials to be held in England.  That was problematic, for, as a subsequent law said:

It hath been found by experience, that Persons committing Piracies, Robberies, and Felonies on the Seas, in or near the East and West Indies, and in Places very remote, cannot be brought to condign Punishment without great Trouble and Charges in sending them into England to be tried within the Realm, as the said Statute directs, insomuch that many idle and profligate Persons have been thereby encouraged to turn Pirates, and betake themselves to that sort of wicked Life, trusting that they shall not, or at least cannot be easily questioned for such their Piracies and Robberies, by reason of the great trouble and expense that will necessarily fall upon such as shall attempt to apprehend and prosecute them for the same.

Consequently, in 1700 Parliament passed the “Act for the More Effectual Suppression of Piracy,” which stated that Vice Admiralty courts (without a jury) in the colonies could try pirates.  These courts were composed of seven commissioners and operated like a military commission.  (The Crown also offered a pirate amnesty and various rewards to merchant vessels if they captured pirates). This was still ineffective, though, because alleged pirates were often able to claim that they were “forced” into the pirate trade against their will and pirate crews worked hard to manufacture phony evidence of this in case someone was captured.  (Leeson discusses this in detail.)  As one prosecutor noted, “[p]lea of constraint of force [was](in the mouth of every Pirate”).  In the end, Leeson concludes that the use of force by the Fleet (more of less blowing up the key pirate bases) was necessary to stop piracy.

In this story we see many of the problems that plague current policy.  It’s difficult to obtain evidence (let alone witnesses) against alleged terrorists from foreign lands.  It’s easy for an alleged terrorist to claim that he is an innocent bystander.  It’s unclear whether jury trials are necessary or not.  Force may be the only solution.  The only thing I would note is that indefinite detention of pirates was never contemplated by the Crown.

Anyway, just food for thought.

My idea for a panel builds on a post that I did wrote way back in April, which talked about what scholars in other fields can learn from Admiralty.  What I would like to do is get a contracts person, a torts person, and a corporate law person to talk about the relevant distinctions between maritime law and land-based doctrine.  I think that could be a fun discussion for lots of folks.  Please email me if you’re interested in participating.

Three Americans were convicted of piracy on the high seas.  A federal law provided for capital punishment where someone on the high seas committed “murder or robbery, or any other offense, which, if committed within the body of the country, would, by the laws of the United States, be punishable with death.”  The defendants argued that their crime was a robbery (no murder was involved) and that robbery was not a capital crime on land.  Thus, they could not be sentenced to death.

Chief Justice Marshall [...]]]> United States v. Palmer, 16 U.S. (3 Wheat.) 610 (1818) is almost certainly the best case on statutory interpretation that you can use in the classroom.  If you’ve never heard of it, that’s because it is a maritime case about pirates.

Three Americans were convicted of piracy on the high seas.  A federal law provided for capital punishment where someone on the high seas committed “murder or robbery, or any other offense, which, if committed within the body of the country, would, by the laws of the United States, be punishable with death.”  The defendants argued that their crime was a robbery (no murder was involved) and that robbery was not a capital crime on land.  Thus, they could not be sentenced to death.

Chief Justice Marshall rejected this interpretation.  He said that the conditional clause about equivalent punishments on land only applied to offenses other than murder or robbery (partly because of the comma after robbery).  If the opposite view was adopted, “robbery on the high seas would escape unpunished.”  He also pointed to other sections of the statute that supported the idea that robbery was singled out for special (and harsher) treatment by Congress.

Justice Johnson dissented.  He argued:  (1) that in doubtful cases courts should construe the scope of the death penalty narrowly; (2) that Congress could not have intended to distinguish robberies on land and sea with different punishments; and (3) that the word “other” made no sense under Marshall’s reading.  In other words, Johnson said that Marshall’s version of the statute should have said “or any offense.”  By saying “any other offense,” though, Congress was indicating that the conditional clause did modify the phrase “murder or robbery.”

I find that this case is really useful in class.  In part, that’s because pirates are involved and thus students are more engaged.  It’s also easy to put the disputed phrase on the board and get people to focus on the text and the competing interpretations.

Let’s start with Koistinen v. American Export Lines, 83 N.Y.S.2d 297 (1948).  Plaintiff was a seaman who was on shore leave in Yugoslavia.  At a bar, he “met a woman whose blandishments, prevailing over his better sense, lured him to her room for purposes not entirely platonic; while there ‘consideration like an angel came and whipped the offending Adam out of him’; the woman scorned was unappeased by [...]]]> Since it’s that time of year (by which I mean exam time), I thought I’d write a recurring series of posts on neat cases that I use in my courses but are relatively unknown.  These will mostly be Admiralty cases, as I doubt that there are any “fun” constitutional or IP decisions that are hidden in plain sight.

Let’s start with Koistinen v. American Export Lines, 83 N.Y.S.2d 297 (1948).  Plaintiff was a seaman who was on shore leave in Yugoslavia.  At a bar, he “met a woman whose blandishments, prevailing over his better sense, lured him to her room for purposes not entirely platonic; while there ‘consideration like an angel came and whipped the offending Adam out of him’; the woman scorned was unappeased by his contrition and vociferously remonstrated unless her unregarded charms were requited by an accretion of ‘dinner,’ . . . the court erroneously interpreted the word as showing that the woman had a carnivorous frenzy which could only be soothed by the succulent sirloin provided at the plaintiff’s expense; but it was explained to denote a pecuniary not a gastronomic dun”

I could go on quoting this opinion all day, but to move things along the seaman (having changed his mind about going through with this assignation) was locked in the room by the woman and confronted by her pimp.  The sailor leapt out the window to escape, fell about eight feet, and broke his leg.  The issue was whether the ship was required to pay maintenance and cure (medical expenses and lost wages) related to his injuries.   The Court said yes, on the grounds that shore-leave injuries (with one or two exceptions) are considered work-related in maritime law.  After all, stranding a sailor in a foreign port with no medical care would be contrary to the remedial goals of maintenance and cure.

Leeson points out that pirates needed to create a legitimate authority amongst themselves because the cost of having unhappy crew members was high. Even one disgruntled pirate could desert and expose the ship to the [...]]]> I just finished a fun book that I want to recommend. It’s “The Invisible Hook: The Hidden Economics of Pirates” by Peter T. Leeson. The author explores the Golden Age of Piracy (circa 1720) and shows how pirates overcame collective action problems. While there are many parts that are of interest to lawyers (for example, the pirate use of trademarks — the Jolly Roger — and crude advertising to enhance their brand of terror and encourage capitulation), the issue that I want to focus on is pirate governance.

Leeson points out that pirates needed to create a legitimate authority amongst themselves because the cost of having unhappy crew members was high. Even one disgruntled pirate could desert and expose the ship to the authorities. (And the penalty for piracy was death). So how did pirate gangs handle this?

First, pirate ships wrote up constitutions (pirate codes) that set forth the rules governing the ship, including punishments for certain offenses and the distribution of loot. Moreover, these codes required unanimous approval to go into effect, which ensured that everyone on the crew “bought into” the rules.

Second, pirate crews elected their captains and officers by majority vote. And these officers could be deposed by a “no confidence” vote at any time. This was an effective enforcement mechanism for the rules set forth in the ship constitution.

Third, pirates divided power between the captain (who was in charge of the ship’s navigation and tactics in battle) and the quartermaster (who was in charge of the ship’s internal operations). This was a formal or constitutional separation that was designed to prevent captain abuse, which was a common problem on merchant ships, by creating checks and balances.

There are lots of other nuggets like this in Leeson’s book. You should check it out.

Since ancient times, pirates have been considered public enemies under customary international law. This meant that ships were free to use force on the high seas to repel or capture pirates. Indeed, the phrase “public enemies” is still used in maritime contracts as a justification for non-performance in the event of a pirate attack. National governments sometimes authorized privateers to attack enemy merchant ships with letters of marque (the Constitution empowers Congress to [...]]]> Piracy is back in the news, and it’s not the intellectual kind. This is great for admiralty professors, and so I thought I’d take advantage of this brief moment in the sun to talk about some general legal issues involving pirates before discussing the ones operating off of Somalia.

Since ancient times, pirates have been considered public enemies under customary international law. This meant that ships were free to use force on the high seas to repel or capture pirates. Indeed, the phrase “public enemies” is still used in maritime contracts as a justification for non-performance in the event of a pirate attack. National governments sometimes authorized privateers to attack enemy merchant ships with letters of marque (the Constitution empowers Congress to issue these in Article One, Section Eight) but these immunity grants from domestic piracy prosecution have not been issued for decades.

Because piracy was difficult to deter, the law turned to the proverbial carrot and stick. For most of our history, piracy against American vessels or committed by Americans was a capital crime. Indeed, a fascinating case that I use in class is United States v. Palmer, 16 U.S. (3 Wheat.) 610 (1818), in which Chief Justice Marshall and Justice Johnson debated whether the federal statute at the time made piracy without murder a capital offense. (This is a wonderful case for those of you who are interested in contrasting methods of statutory interpretation.) On the civil side, the law of “maintenance and cure” provided that a crew member who was disabled defending a ship against a pirate attack was entitled to a lifetime of medical care, whereas normally injured sailors were entitled to nothing after the voyage ended.

With respect to the pirates in Somalia, two points stand out. The first is that there is some ambiguity in international law about what nations can do to suppress piracy within territorial waters or on land. While a country that harbors pirates can be sanctioned (much like a country that hosts terrorists), it is not clear that a casus belli exists just because pirates are there. Granted, one could make a powerful argument (at least it sounds good to me) that Somalia has not had a government for nearly twenty years, and thus there is no sovereignty to violate. Nevertheless, this legal issue might explain the lack of action so far.

The other point is political. My sense is that the real reason that no action is being taken against the pirates is that they are, sad to say, the only alternative to the radical Islamist movement in Somalia. Indeed, Ethiopia invaded the country a few years ago to prevent the creation of an Islamist there, and the pirates took advantage of the resulting vacuum to establish themselves. Does anyone want to eliminate the pirates and see what would happen next? I doubt it.

New Jersey has threatened to pull state pension funds from Delaware banks. Delaware officials, meanwhile, talked about calling up its National Guard to guard its border. . . . [A] New Jersey legislator wondered aloud about recommissioning the battleship New Jersey, now a museum on the Camden waterfront, just in case.

The majority agreed . . . that New Jersey could not authorize activities “beyond the exercise of ordinary and usual riparian rights in the face of contrary [...]]]> The state of Delaware has just won a major dispute with New Jersey in the Supreme Court, over a vigorous dissent by Justice Scalia. The dispute concerned New Jersey’s plan to build a “huge gas-processing plant on the Jersey side of the Delaware River.” As the NYT reports,

New Jersey has threatened to pull state pension funds from Delaware banks. Delaware officials, meanwhile, talked about calling up its National Guard to guard its border. . . . [A] New Jersey legislator wondered aloud about recommissioning the battleship New Jersey, now a museum on the Camden waterfront, just in case.

The majority agreed . . . that New Jersey could not authorize activities “beyond the exercise of ordinary and usual riparian rights in the face of contrary regulation by Delaware.” Justice Antonin Scalia . . . professed to be flabbergasted by the majority’s reasoning. What was so “extraordinary” about a wharf to unload liquefied natural gas, he asked. “Would a pink wharf, or a zig-zagged wharf qualify? How about one for the transfer of “tofu and bean sprouts”?

It all reminds me of a classic 2002 article by Jon Chait charging Delaware with persistent disregard for other states’ interests. . . .

The practice of charging road tolls is an archaic holdover blighting much of the Northeast. But Delaware has taken it to a grotesque extreme. Whereas the I-95 tolls amount to less than five cents per mile in New Jersey and four cents per mile in Maryland, in Delaware they cost an exorbitant 18 cents per mile. Which isn’t surprising because, in a deeper sense, Delaware’s tolls epitomize the state’s entire ethos. The organizing principle of Delaware government is to subsidize its people at the rest of the country’s expense.

[But not] all the instruments of Delaware’s rapacity take the form of meddlesome, high-handed government exacting inflated costs on out-of-state visitors. When need be, the state’s avarice can also be fed by the exact opposite. An example of this latter technique is Delaware’s enticement of much of the banking industry to relocate within its borders. It did so in 1981 not only by offering special tax breaks–the standard formula that states and localities use to woo industry–but by eviscerating its usury laws, which limit the interest a bank can charge for loans or credit cards.

[S]till, perhaps the prime example of what Louis D. Brandeis called the regulatory “race to the bottom” is Delaware’s biggest scam: incorporation fees. It so happens that in excess of 300,000 corporations–including half of the Fortune 500– incorporate in wee Delaware. . . . Delaware propaganda suggests it is primarily a function of the state’s efficient bureaucracy and legal system, which includes a chancery court (a chamber specializing in business disputes). This is partly true, but it ignores the overriding factor:. . . its laws are specifically crafted to appeal to the interests of corporate executives.

All of this is deliberate state policy. A hundred years ago, in fact, the great trusts preferred to incorporate in New Jersey, not Delaware. It was only when New Jersey, under the progressive-era governorship of Woodrow Wilson, altered its laws to take account of interests (other than management) that corporations began to flee across the Delaware River.

Jon Chait’s laments will be no surprise to those who run the “race to the bottom” blog. (As Tim Glynn notes, “Delaware’s jurists are willing to go beyond the traditional norms of judicial behavior to advance Delaware’s interests.”) Nevertheless, I may just end up on Delaware’s side in this particular dispute. New Jersey’s proposal doesn’t exactly sound enviro-friendly–and as one who commutes through the chemical tanks of Kearny, NJ on a daily basis, I’m not exactly confident in the state’s environmental record.

O the posh posh traveling life, the traveling life for me

Pardon the dust of the upper crust – fetch us a cup of tea

Port out, starboard home, posh with a capital P. . .

Admittedly, for those of us crushed into coach, there was always a happy flipside to the narrative: the profligates up front were paying so much more for their seats, effectively subsidizing the rest of us.

But that subsidy effect has been on [...]]]> Travel has always served to remind us of the divisions our “classless society” tries so hard to downplay. Sam Walton may have driven an old truck, but you’d be hard-pressed to find most top executives or trust-funders flying in less-than-first-class digs. As the song in Chitty-Chitty Bang-Bang put it,

O the posh posh traveling life, the traveling life for me

Pardon the dust of the upper crust – fetch us a cup of tea

Port out, starboard home, posh with a capital P. . .

Admittedly, for those of us crushed into coach, there was always a happy flipside to the narrative: the profligates up front were paying so much more for their seats, effectively subsidizing the rest of us.

But that subsidy effect has been on the wane in recent years. And now wealthy fliers have found a new way to effectively assure that the rest of us are subsidizing them:

Corporate jets pay a fraction of the taxes and fees that commercial airliners do. The F.A.A. estimates that private planes, which include both corporate jets and weekend fliers, account for 16 percent of the air traffic control system’s overhead but contribute only 3 percent of the fees earmarked to run the system.

***

The Air Transport Association has . . . created a Web-based ad campaign featuring a fictional traveler, Edna, complaining about the fee disparity while the computer screen displays waves of corporate jets filling the skies before and after sporting events like the Kentucky Derby and the Masters golf tournament.

It’s enough to wilt the mint in your julep. As the campy YouTube ad sloganeers, travelers like “wearing big wigs, not subsidizing them!” Edna (pictured above) wonders “Why should the rest of us pay ten times more using the same services?”

Fortunately, the FAA has heard her pain, and is planning on “sharply increasing the fuel tax for private jets and also hitting corporate fliers with extra charges to land at any of the country’s 30 most congested airports.”