Marine league

compared to that of the coastal states which boast a three marine league

as three marine leagues from the coast, including all islands.

Engerrand, DOHSA's Reach: What Are the High Seas Beyond a Marine League From Shore?, 1 LOY.

The district court found "persuasive the [portion of the] dissenting opinion of Judge Sotomayor" stating that, by including the phrase "beyond a marine league," Congress intended to avoid confusion and make clear that DOHSA only applied outside state territorial boundaries.

In 1916, the phrase "beyond a marine league [i.e., three nautical miles] from the shore of any [s]tate..." was added after "on the high seas" to emphasize that the territorial seas and navigable internal waters of the U.S.

The most natural reading of this text is that a death must occur both on the high seas and beyond a marine league from the shore for DOHSA to apply.

(77) This draft granted a wrongful death remedy in the federal district courts in admiralty for deaths caused by wrongful acts on the high seas beyond a marine league from the shore of any state or on any navigable waters of the Panama Canal Zone, the District of Columbia or the territories or dependencies of the United States.

2085 was endorsed by the MLA and ABA (91) and was the result of a compromise by which a federal wrongful death action was enacted for the high seas beyond a marine league from shore (92) but the remedy for wrongful death in state territorial waters was left to state statutes.