Yamaha Motor Corp., USA v. Calhoun
516 U.S. 199, 133 L. Ed. 2d 578, 1996 U.S. LEXIS 463 (1996)
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Rule of Law:
The federal maritime cause of action for wrongful death does not displace state law remedies for the deaths of non-seafarers killed in state territorial waters.
Facts:
- On July 6, 1989, twelve-year-old Natalie Calhoun was vacationing with family friends at a resort in Puerto Rico.
- Natalie rented a “WaveJammer” jet ski manufactured by Yamaha Motor Company, Ltd., and distributed by Yamaha Motor Corporation, U.S.A. (collectively, Yamaha).
- While riding the jet ski in the navigable waters off the hotel, Natalie collided with an anchored vessel.
- As a result of the collision, Natalie was killed.
- Natalie was a non-seafarer, meaning she was not a seaman, longshore worker, or otherwise engaged in a maritime trade.
Procedural Posture:
- Lucien and Robin Calhoun sued Yamaha in the U.S. District Court for the Eastern District of Pennsylvania, invoking state wrongful-death statutes.
- Yamaha filed a motion for partial summary judgment, arguing that the federal maritime wrongful-death action was the exclusive remedy.
- The District Court held that the federal maritime action displaced state remedies.
- The District Court then certified an order for an immediate interlocutory appeal to the U.S. Court of Appeals for the Third Circuit.
- The Third Circuit held that state-law remedies apply and were not displaced by federal maritime law.
- The U.S. Supreme Court granted certiorari to review the Third Circuit's decision.
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Issue:
Does the federal maritime wrongful-death action recognized in Moragne v. States Marine Lines, Inc. provide the exclusive remedy for the death of a non-seafarer in state territorial waters, thereby displacing state-law remedies?
Opinions:
Majority - Justice Ginsburg
No. The federal maritime wrongful-death action does not provide the exclusive remedy for the death of a non-seafarer in state territorial waters, and state law remedies are not displaced. The Court reasoned that its prior decision in Moragne, which established a general maritime action for wrongful death, was intended to extend relief, not to contract available remedies. The uniformity concerns that drove the Moragne decision were specific to anomalies affecting maritime workers and the distinctly maritime doctrine of unseaworthiness, not to create a uniform federal scheme for all deaths on navigable waters. Historically, federal admiralty courts have applied state wrongful-death statutes, and Moragne was a gap-filling measure to address injustices, particularly for maritime workers, not a ceiling on recovery designed to preempt state law for non-seafarers.
Analysis:
This decision preserves a significant role for state law within federal admiralty jurisdiction, especially in cases involving non-maritime workers like recreational boaters. It clarifies that the Moragne remedy was created to solve specific uniformity problems related to maritime workers and the unseaworthiness doctrine, not to create a single, exclusive federal scheme for all deaths on navigable waters. The ruling ensures that victims' families in such cases can access potentially more generous state-law damages, such as for loss of society or lost future earnings, which may not be available under a uniform federal maritime rule. This creates a clear distinction in remedies available for maritime workers versus non-seafarers in territorial waters.
