Miles v. Apex Marine Corp.
498 U.S. 19, 112 L. Ed. 2d 275, 1990 U.S. LEXIS 5688 (1990)
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Rule of Law:
Under general maritime law, damages in a wrongful death action for a seaman do not include non-pecuniary losses like loss of society, and a survival action may not include recovery for the decedent's lost future earnings, in order to promote uniformity with the remedies established by Congress in the Jones Act and the Death on the High Seas Act (DOHSA).
Facts:
- Ludwick Torregano was a seaman employed aboard the vessel M/V Archon, which was operated by Apex Marine Corporation and other related companies (Apex).
- On July 18, 1984, while the ship was docked in Vancouver, Washington, a fellow crew member, Clifford Melrose, repeatedly stabbed Torregano.
- Torregano died from the injuries sustained in the stabbing.
- Mercedel Miles, Torregano's mother, is the administratrix of his estate.
Procedural Posture:
- Mercedel Miles sued Apex Marine Corp. in the U.S. District Court for the Eastern District of Louisiana, asserting claims for negligence under the Jones Act and unseaworthiness under general maritime law.
- The District Court ruled that the estate could not recover for Torregano's lost future income.
- A jury found Apex negligent but the vessel seaworthy, and finding that Miles was not financially dependent on her son, denied her recovery for loss of society.
- Miles (appellant) appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals held that the vessel was unseaworthy as a matter of law, but affirmed the District Court's denial of damages for loss of society and lost future earnings under general maritime law.
- Miles (petitioner) was granted a writ of certiorari by the U.S. Supreme Court to review the denial of damages for loss of society and lost future income.
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Issue:
Under general maritime law, may the parent of a deceased seaman recover damages for loss of society, and may the seaman's estate bring a survival action to recover the seaman's lost future earnings?
Opinions:
Majority - Justice O'Connor
No, under general maritime law, the parent of a deceased seaman may not recover damages for loss of society, and the seaman's estate may not bring a survival action to recover the seaman's lost future earnings. Admiralty courts must look to federal statutes like the Jones Act and the Death on the High Seas Act (DOHSA) for policy guidance. The Jones Act, which governs negligence claims for seamen, incorporates FELA, which has been consistently interpreted to allow recovery only for pecuniary losses, thereby excluding loss of society. It would be inconsistent to permit more expansive remedies for a judicially-created cause of action (unseaworthiness) than Congress has allowed for a statutory negligence claim. Similarly, the Jones Act's survival provision limits recovery to losses suffered during the decedent's lifetime and does not permit recovery of lost future income. Therefore, a general maritime survival action for a seaman cannot provide for a remedy that Congress has foreclosed in the analogous statutory scheme, as the primary goal is to maintain a uniform rule applicable to all actions for the wrongful death of a seaman.
Analysis:
This case significantly curtails the scope of available damages under the general maritime cause of action for wrongful death created in Moragne. The Court establishes the principle that judicially-created maritime remedies must conform to the limitations set forth by Congress in related statutory schemes, such as the Jones Act. This decision prioritizes uniformity in maritime law over the judiciary's traditional 'special solicitude' for seamen, signaling a strong deference to legislative policy in determining the scope of remedies in maritime tort law and limiting the power of federal courts to expand them.
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