Norfolk Shipbuilding & Drydock Corp. v. Garris
Headline: Court allows wrongful-death claims under federal maritime law when negligence causes death, letting families of nonseamen killed in territorial waters seek damages in federal maritime court rather than being limited to state remedies.
Holding: The Court held that general maritime law recognizes a wrongful-death cause of action for deaths caused by negligence, allowing families of nonseamen killed in U.S. waters to recover under federal maritime law.
- Allows families of nonseamen killed by maritime negligence to sue under federal maritime law.
- Clarifies that Jones Act, DOHSA, and LHWCA do not bar such federal wrongful-death claims.
- Leaves factual issues about duty and breach for lower courts to resolve on remand.
Summary
Background
A mother sued after her son, Christopher Garris, was injured while sandblasting aboard a ship and died the next day. He worked for a subcontractor on a vessel berthed in U.S. navigable waters. The mother sought damages under federal maritime law and also filed a state wrongful-death claim; the federal trial court dismissed the maritime claim as unavailable, but the federal appeals court reversed, and the case reached this Court.
Reasoning
The central question was whether a negligent breach of a maritime duty that causes death should be actionable under general maritime law the same way it is for nonfatal injury. The Court found no sensible reason to treat negligence differently from the seaworthiness duty already covered by prior wrongful-death law. It examined relevant federal statutes — the Jones Act, DOHSA, and the Longshore and Harbor Workers’ Compensation Act — and concluded those laws do not bar a federal negligence-based wrongful-death remedy for a nonseaman killed in territorial waters. The Court therefore held that general maritime law recognizes wrongful-death claims for deaths caused by negligence and affirmed the appeals court.
Real world impact
The ruling lets families of nonseamen killed by maritime negligence bring federal wrongful-death claims rather than relying only on state law or limited statutory routes. The decision does not resolve factual questions about duty or breach, which can be raised on remand. It also includes a note that courts should harmonize federal maritime law with Congress’s statutes when appropriate.
Dissents or concurrances
Justice Ginsburg agreed in large part but cautioned that development of maritime law should be a shared effort between courts and Congress, disagreeing with part of the Court’s language about leaving some developments to Congress.
Opinions in this case:
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