in eats, shoots and leaves, lynn truss states the following:
"Current guides to punctuation state that with modern names ending in "s", the "s" is required after the apostrophe:
Keats's poems
Philippa Jones's book
With names from the ancient world it is not:
Archimedes' screw
Achilles' heel
If the name ends in an "iz" sound, an exception is made:
Bridges' score
Moses' basket
And, and exception is always made for Jesus:
Jesus' disciples.
However, these are matters of style and preference that are definitel not set in stone, and it's a good idea not to get fixated about them.... Consulting a dozen or so recently published punctuation guides, I can report that they contain minor disagreements on virtually all aspects of the above."
So... it would seem that there are no actual set rules about the use of the apostrophe in this context. Which is rather good because it means you can never get it wrong!