The 1999 decision in Lubrano v. Waterman Steamship Co., 1999 AMC 1709 (2d Cir.), is another step by the federal courts to limit the application of one of the most famous and effective judge-created remedies in U.S. admiralty and maritime law — the shifting of loss under the Ryan implied warranty of workmanlike performance. Indemnity is an all or nothing…

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