to shipments that are lost at sea. Tropical correctly assesses our reluctance to hold that a container is a package, where more accurately it may be considered but “a modern substitute for the hold of the vessel.” Northeast Marine Terminal Co. v. Caputo, 432 U.S. 249, 270, 97 S.Ct. 2348, 53 L.Ed.2d 320 (1977). In fact: [W]e cannot escape the belief that the purpose of § 4(5) of COGSA was to set a reasonable figure below which the carrier should not be permitted to limit his liability and that “package” is thus more sensibly related to the unit in which the shipper packed the goods and described them than to a large metal object, functionally a part of the ship, in which the carrier caused them to be “contained.” Leather’s Best, Inc. v. S.S. Mormaclynx, 451 F.2d 800, 815 (2d Cir.1971) (<HOLDING>); see also Allstate, 646 F.2d at 172-173
holding that the relevant time is the time of the employment decision holding that the plaintiffs placement on paid administrative leave constituted an adverse action for purposes of a first amendment retaliation claim holding that the 99 bales of leather inside a container constituted the relevant package for cogsa purposes holding that the relevant time of inquiry is the date of the filing of the complaint holding that alcohol odor provided probable cause to search vehicle for open container and smell of burnt marijuana justified search of entire vehicle for drugs