The SS Zoe Colocotroni, a tramp-oil tanker, grounded on a reef off the coast of Puerto Rico. In order to free the ship, the captain dumped the cargo of crude oil into the ocean, which floated towards the coast and entered a Puerto Rican Bay called Bahia Sucia and the mangrove forests nearby. The Commonwealth of Puerto Rico and the Local Environmental Quality Board brought an action to recover damages for the environmental harm caused by the oil spilling.

The federal district court awarded damages based on the replacement costs of the high number of marine animals killed.