Moragne v. States Marine Lines, Inc.
398 U.S. 375 (1970)
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Rule of Law:
An action for wrongful death based on unseaworthiness is cognizable under general federal maritime law.
Facts:
- Edward Moragne, a longshoreman, was employed by Gulf Florida Terminal Company.
- Moragne was working aboard the vessel Palmetto State, which was owned by States Marine Lines, Inc.
- The vessel was located in navigable waters within the State of Florida.
- While performing his duties on the vessel, Moragne was killed.
- The death was allegedly caused by the unseaworthiness of the vessel, a violation of maritime duties.
Procedural Posture:
- Petitioner Moragne's widow sued the vessel owner, States Marine Lines, Inc., in a Florida state court.
- States Marine removed the case to the U.S. District Court for the Middle District of Florida and filed a third-party complaint against the decedent's employer, Gulf Florida Terminal Company.
- The defendants moved to dismiss the wrongful death claim based on unseaworthiness, arguing it was not available under either maritime or Florida law.
- The District Court dismissed that portion of the complaint.
- The District Court certified the order for an interlocutory appeal to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals certified a question to the Florida Supreme Court on whether the state's wrongful death act allowed recovery for unseaworthiness.
- The Florida Supreme Court answered the certified question in the negative.
- The U.S. Court of Appeals for the Fifth Circuit affirmed the District Court's dismissal, citing binding Supreme Court precedent.
- The U.S. Supreme Court granted certiorari to reconsider the issue.
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Issue:
Does general federal maritime law, which provides a remedy for personal injuries short of death, afford a cause of action for wrongful death caused by a violation of maritime duties?
Opinions:
Majority - Mr. Justice Harlan
Yes, an action for wrongful death is available under general maritime law. The Court's 1886 decision in The Harrisburg, which held that maritime law does not afford a cause of action for wrongful death, is overruled. The original justification for the common-law rule against wrongful death actions—the felony-merger doctrine—was never applicable in the United States and is an archaic relic. Furthermore, the overwhelming trend in both state and federal legislation, including the Death on the High Seas Act and the Jones Act, demonstrates a strong and uniform public policy in favor of allowing recovery for wrongful death, making the old maritime rule an unjustifiable anomaly. Overruling The Harrisburg promotes uniformity in admiralty law, eliminating the incongruity where recovery is allowed for injury but not death, and where liability depends on the happenstance of state law for deaths in territorial waters.
Analysis:
This landmark decision overruled the nearly century-old precedent of The Harrisburg, creating a new, judicially-fashioned federal cause of action for wrongful death under general maritime law. It eliminated a significant and unjust anomaly where a claim for unseaworthiness could be brought for injury but not for death in territorial waters. The ruling significantly advanced the constitutional principle of uniformity in maritime law by ensuring that federal remedies apply consistently, rather than depending on the varying scope of state wrongful-death statutes. This case serves as a powerful example of the Supreme Court's role in shaping and modernizing admiralty law to align with contemporary policy and legislative trends.
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