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Cargo congestion has reached historic proportions during the COVID-19 pandemic as the demand for imports by U.S. consumers and businesses has skyrocketed combined with an increase in operational disruptions.

On March 28, 2011 the U.S. Court of Appeals for the Ninth Circuit rejected an appeal by the Pacific Merchant Shipping Association ("PMSA"), a mutual benefit corporation comprised of owners and operators of U.S. and foreign-flag vessels, in which it sought to prevent the state of California from expanding its enforcement of vessel fuel standards to 24 miles, well beyond the state's traditional 3-mile territorial limit.