The liability of the carrier is one of the most important issues in maritime collision law. This article considers an oft-overlooked but nonetheless important aspect of collision liability: Both-to-blame clauses and their operation when collisions occur on United States territorial waters, and, in particular, the issues that confronted the federal district court in considering such a clause’s application in <I>In re Complaint of Murmansk Shipping Co.,</I> 2001 WL 699530 (E.D. La. 2001)