The following excerpt is from Barnes v. Sea Haw. Rafting, LLC, 889 F.3d 517 (9th Cir. 2018):
19 From the 1940s until the 1980s, the reasonable rate was generally held by courts to be eight dollars per day, despite the deteriorating value of that fixed amount over four decades. See Gardiner v. SeaLand Serv., Inc. , 786 F.2d 943, 946 (9th Cir. 1986). More recently, "courts have allowed [a] seaman to prove that higher costs of living require a higher maintenance amount." 8 Benedict et al., supra , 10.02[C][4].
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