American Export Lines, Inc. v. Alvez

Background

Gilberto Alvez lost an eye while working as a lasher aboard a ship in New York waters. He sued the shipping company for negligence and unseaworthiness. The trial court initially would not add his wife to claim for loss of her husband’s society, but New York appellate courts allowed the claim and the highest state court approved it. The United States Supreme Court agreed to review the question and then affirmed the state court’s decision.

Reasoning

The core question was whether general maritime law lets a wife recover for loss of her husband’s society when he is injured but not killed. The Court relied on prior decisions that created nonstatutory maritime remedies for wrongful death and related injuries. It said there is no logical reason to limit recovery for loss of society to fatal cases. The Court also explained that federal statutes covering deaths on the high seas and certain worker remedies do not bar a judge-made maritime remedy here. The majority emphasized admiralty’s tradition of giving remedies to injured seafarers and their families, and noted a majority of states already allow similar spouse recovery.

Real world impact

The result lets spouses of harbor and shipboard workers seek money for loss of companionship, care, and support after nonfatal injuries. In practical terms, courts can award damages for the emotional and practical losses a spouse suffers when a worker is badly hurt on the job. The Court resolved a split among lower courts and made such claims available under general maritime law.

Dissents or concurrances

One Justice joined the judgment but noted he thought earlier related precedent was wrong. A dissent argued the Supreme Court lacked jurisdiction because the state proceedings were not finally settled when review was granted.