Yamaha Motor Corp., USA v. Calhoun

Background

Twelve‑year‑old Natalie Calhoun died in a jet‑ski collision in territorial waters off Puerto Rico. Her parents sued the jet‑ski maker, alleging the craft was defectively designed and seeking damages under Pennsylvania wrongful‑death and survival laws. The manufacturer argued that federal maritime law — a judge‑made maritime wrongful‑death action recognized in prior cases — displaced those state remedies and limited recovery. The case was filed in federal court invoking diversity and admiralty jurisdiction; the district court initially held that the prior maritime rule displaced state remedies, prompting interlocutory appeal to the Court of Appeals.

Reasoning

The Court asked whether the federal maritime wrongful‑death action replaces state wrongful‑death and survival remedies for non‑seafarers who die in territorial waters. The Court explained that admiralty jurisdiction does not automatically oust state law. Moragne, the earlier decision recognizing a maritime wrongful‑death cause of action, was intended to fill gaps affecting seamen and to ensure unseaworthiness claims were not denied, not to eliminate state remedies for ordinary water‑related accidents. The opinion emphasized that Moragne aimed to remove unfair anomalies affecting seamen, not to place a ceiling on recoveries for ordinary accidents. The Court also relied on Congress’s message in the Death on the High Seas Act that state remedies should not be affected. Applying these principles, the Court agreed with the Third Circuit and held that state remedies remain available.

Real world impact

The ruling lets families of non‑seafarers who die in territorial waters pursue state wrongful‑death and survival claims against manufacturers and others. It preserves damages available under state law — such as loss of society, future earnings, and funeral costs — though which State’s law applies and whether federal or state standards govern liability were left for later proceedings. The Court left open which State’s law — Pennsylvania or Puerto Rico — governs, and it reserved for another day whether federal maritime rules or state standards will determine the applicable liability rules.