I just saw this 2009 article Can a Whale Get Rabies? which includes this statement,
Although there is absolutely no record of a rabid whale, and only one documented case of rabies in a seal—a ringed seal caught in 1980 in Svalbard, an archipelago off Norway—the scenario may soon be of greater concern. "Starting 10 years ago, coyotes began to prey on harp seals here on Cape Cod," Moore says. "Because of that, I like for my staff to get vaccinated. There's a very small chance that a seal will have rabies."
It would seem that there is a vector for rabies to cross oceans and potentially infect land mammals, slight but plausible... It has been nearly 10 years since the article.
Is there any documentation of a person getting rabies from a marine mammal?