decision. The 1936 amendment made explicit the applicability to foreign shipowners, stating "The liability of the owner of any vessel, whether American or foreign ... shall not, except in the cases provided for ... exceed the amount or value of the interest of such owner in such vessel, and her freight then pending". Rev. Stat. §4281–89 eventually were moved to 46 U.S.C. App. Ch. 8, and then to in 2010. Invocation Historically, the statute has been invoked to limit the liability of certain parties in the sinking of RMS Titanic (1912), the Deepwater Horizon oil spill (2010), and the sinking of MV Conception (2019). In the case of , the district court judge initially ruled that British liability of limitation law would apply, but that decision was reversed by the United States Supreme Court in 1914. Recent developments The Deepwater Horizon Survivors' Fairness Act was introduced in the Senate and sought to amend the Limitation of Liability Act to make an exception for personal injuries and wrongful death claims related to the explosion and destruction of the Deepwater Horizon oil drilling platform. It was referred to the Committee on Commerce, Science, and Transportation. The Congressional Budget Office provided a cost estimate. Parallel bills were introduced simultaneously in the House and Senate in September 2021 to amend the Limitation of Liability Act. As originally written, the bills would take effect retroactively to September 2, 2019 and apply to the sinking of MV Conception. References Public liability United States federal admiralty and maritime legislation