Does the breach day rule apply when damages become certain?

In another application of the breach-day rule, the court in Jamaica Nutrition Holdings v. United Shipping, supra, 643 F.2d 376, also focused on when the plaintiff's damages became certain. Soybean oil was sent by ship from Louisiana to a purchaser in Jamaica. Traces of molasses were discovered in the oil, which then had to be reprocessed by the purchaser; the cost of the reprocessing was incurred in Jamaican dollars. The appellate court stated that when the shipowner breached its duty to make the vessel seaworthy, the plaintiff had a claim for damages, with only the exact amount of those damages remaining to be calculated. The court then concluded that the damages should be converted into United States dollars on the date the reprocessing costs were incurred and paid for in Jamaica. (Id., at pp. 380-381.)

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