Lindgren v. United States

Background

A seaman working as third mate on a United States‑owned merchant ship was killed when a lifeboat fell while the ship was in a Norfolk drydock. His administrator sued the United States in federal admiralty, alleging negligence and asking for damages on behalf of any dependents. The district court found negligence and awarded damages under Virginia’s wrongful‑death statute, but the court of appeals reversed, holding federal law displaced the state statute.

Reasoning

The Court addressed whether Congress’s Merchant Marine Act §33 — which adopts parts of the Federal Employers’ Liability Act (FELA) for seamen — leaves room for state death statutes or older admiralty remedies. The Court explained that before Congress acted, admiralty did not authorize recovery for a seaman’s death; Congress then created a uniform federal rule. Section 33 gives a personal representative a right to sue only to recover for specified surviving beneficiaries named by the incorporated FELA rules. If no such beneficiaries exist, there is no federal cause of action. Because the Merchant Marine Act is a general federal law covering the whole field, it displaces state death statutes and does not allow separate admiralty indemnity for death.

Real world impact

The decision means seamen’s death claims are governed by the federal scheme Congress chose. State wrongful‑death laws cannot be used when the federal law applies, and no recovery exists when the statute’s beneficiary classes include no survivors. The Court did not decide issues about deaths on the high seas or other federal compensation statutes.