Offshore Logistics, Inc. v. Tallentire

Background

Two widows sued after helicopters owned by a company crashed about 35 miles off Louisiana, killing their husbands, who worked on offshore drilling platforms. They sued under the federal Death on the High Seas Act (DOHSA), the Outer Continental Shelf Lands Act (OCSLA), and Louisiana wrongful-death law. The federal trial court held DOHSA exclusive and awarded only pecuniary damages; the Fifth Circuit allowed Louisiana’s broader damage measure and the Supreme Court reviewed the conflict.

Reasoning

The core question was whether federal law or Louisiana law controls when a death occurs beyond a state’s territorial waters. The Court said OCSLA did not apply because the accident happened on the high seas, and DOHSA by its terms covers deaths occurring beyond a marine league. The Court read DOHSA’s §7 as a jurisdictional saving clause that preserves state courts’ ability to hear DOHSA claims but does not allow state laws to change DOHSA’s damages rules. Emphasizing Congress’ aim for uniform remedies on the high seas, the majority reversed the Fifth Circuit and held that state nonpecuniary damages are not available here.

Real world impact

Families of people killed beyond three miles from shore cannot use state wrongful-death damage rules to get wider awards; DOHSA’s pecuniary-only standard governs. DOHSA also limits beneficiaries to immediate family members and measures recovery as fair and just compensation for pecuniary loss. The Court left some narrow survival-claim questions unresolved.

Dissents or concurrances

Justice Powell, joined by three Justices, disagreed, arguing §7 plainly preserved state remedies on the high seas and would permit state damage rules to apply.