The topographic distribution, density, and size of ganglion cells were studied in retinal wholemounts of the sea otter, Enhydra lutris. The cell distribution showed a well defined horizontal streak of higher cell density, and within this streak, a narrow area of the highest cell density. The peak cell density in this area ranged from 4050 to 4400 cells/mm2, with a mean of 4225 cells/mm2. The ganglion cell size ranged from 7 μm to 47 μm, but the majority of cells were 7 to 30 μm. Cell size distribution revealed three size groups: 7–16, 17–28, and 29–47 μm. The highest-density area contained mainly small (7–16 μm) cells. The cell-density data predict a retinal resolution around 7’ in water. Retinal organization in the sea otter exhibits more properties common with terrestrial rather than aquatic mammals, both in terms of ganglion cell characteristics and in terms of their topographic distribution.