Container ports from coast to coast are inundated with empty cargo containers. The Federal Maritime Commission has commenced an investigation into America’s import and export flows, as many ports are overcrowded with empty containers that have yet to be collected or transported back to their point of origin. Carriers that fail to remove empty containers from the port run the risk of incurring fines or penalties, but there is widespread inconsistency with regard to port authorities and their enforcement practices. In addition, the global pandemic has exacerbated container congestion, as shipping flows reached an all-time high in 2020 and citizens around the world have become increasingly reliant on online retailers to deliver household goods.