Yamaha Motor Corp v Calhoun Doc 94-1387 decided Jan 9, 1996
The Supreme Court decided that wrongful death cases originating on recreational boats where the decedent was not a seaman, harbor worker or longshoreman could be governed by state law.
The case involved a twelve year old girl who was killed in a collision in territorial waters off Puerto Rico while riding a jet ski manufactured by the petitioners, Yamaha Motor Corp. A federal diversity and admiralty action was filed against Yamaha seeking damages and invoking Pennsylvania's wrongful death and survival statute. The District Court agreed with Yamaha that the federal maritime wrongful death action recognized in Morange v. States Marine Lines, Inc., 398 U.S. 375 controlled to the exclusion of state law. The appellant court held, in reversing the District Court, that state remedies remain applicable in accident cases of this type and have not been displaced by the federal maritime wrongful death action recognized in Morange which severely limited damages. 40 F. 3d 622 (1994).
The Supreme Court reviewed the history of wrongful death actions. In The Harrisburg, 119 U.S. 199, (1886) the Supreme Court held that general maritime law (a species of judge-made federal common law) did not afford a cause of action for wrongful death. The Harrisburg Court said that wrongful death actions are statutory and may not be created by judicial decree. The Court noted that common law in the United States like that in England and other countries, did not allow recovery for an injury which results in death. Federal admiralty courts tempered the harshness of The Harrisburg's rule by allowing recovery under state wrongful death statutes. State wrongful death statutes proved an adequate supplement to federal maritime law, until a series of decisions by the Supreme Court transformed the maritime doctrine of unseaworthiness into a strict liability rule.
Prior to 1944, unseaworthiness was an obscure and relatively little used liability standard, largely because a shipowner's duty at that time was only to use due diligence to provide a seaworthy ship. A series of cases changed the standard and the duty to furnish a vessel and appurtenances reasonably fit for their intended purpose became absolute - a failure to supply a safe ship resulted in liability irrespective of fault and irrespective of the intervening negligence of the crew members. Miles v Apex Marine Corp., 498 U.S. 19 (1990).
The disparity between the unseaworthiness doctrine's strict liability standard and the negligence-based state wrongful death statutes figured prominently in the Court's landmark Morange decision. In Morange, the Court reexamined the soundness of The Harrisburg and decided that its holding, "somewhat dubious even when rendered, is such an unjustifiable anomaly in the present maritime law that it should no longer be followed." 398 US at 378. Accordingly, it overruled The Harrisburg decision and held that an action "lie[s] under general maritime law for death caused by violation of maritime duties." 398 U.S., at 409.
Yamaha argued the "maritime duties" owed to maritime workers covers the waters, creating a uniform federal maritime remedy for all deaths occurring in state territorial waters, and ousting all previously available state remedies. In Yamaha's view, state remedies can no longer supplement general maritime law (as they routinely did before Morange), because Morange launched a solitary federal scheme.
The Court analyzed it holding in Morange concluding that the uniformity concern that drove its decision in Morange related not to excessive awards in some states, but instead, to the availability of unseaworthiness as a basis of liability. When Congress prescribed a comprehensive tort recovery regime to be uniformly applied, there is, the court stated, no cause for enlargement of the damages statutorily provided. But Congress did not prescribe remedies for the wrongful deaths of non-seafarers in territorial waters. Recognizing this, the Court preserved the application of state statutes to deaths within territorial waters for recreational boaters.
Thus, in a major decision, the Supreme Court ruled unanimously that the federal limitation of liability is not applicable to pleasure boat death cases and that families may seek wide-ranging monetary damages in state courts.
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