Marine insurance contracts were one of the most important categories of federal litigation in the early nineteenth century. The increase in international conflict resulted in a corresponding increase in the risk associated with maritime activity and the number of claims insurance companies litigated in an effort to minimize losses. Accordingly, a rich body of commercial law was developed by the federal courts in which the cases were tried. One such case was McCall v. Marine Insurance Company, in which the Supreme Court determined the impact of the addition of a single unusual word in the clause that set forth the risks protected against, employing principles of the law of nations as well as principles of contractual construction
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