Norfolk Shipbuilding & Drydock Corp. v. Garris
The Supreme Court ruled that families can sue for wrongful death under general maritime law when a worker dies because of someone's negligence on navigable waters, not just when death results from an unseaworthy ship.
The decision closes a gap left open by the Court's 1970 ruling in Moragne, extending the same wrongful-death protection to negligence claims and ensuring that a worker's death is not treated as legally less serious than a survivable injury.
“Where existing law imposes a primary duty, violations of which are compensable if they cause injury, nothing in ordinary notions of justice suggests that a violation should be nonactionable simply because it was serious enough to cause death.”
The Court's core reasoning for why fatal negligence should be treated the same as non-fatal negligence.
How it got here: A federal trial court dismissed the maritime negligence claim; the Fourth Circuit reversed and allowed it; the shipyard asked the Supreme Court to review that reversal.
The Case in Depth
What happened
A young worker, Christopher Garris, was injured while sandblasting aboard a Navy support ship berthed in Virginia waters and died the next day. He worked for a subcontractor hired by another subcontractor of Norfolk Shipbuilding & Drydock Corporation. His mother sued, claiming his death resulted from negligence by the shipyard and another subcontractor, and sought damages under general maritime law and Virginia's wrongful-death statute.
The question before the Court
If a careless act on a ship kills a worker who isn't a sailor, can his family sue for wrongful death under general maritime law?
Why it matters
Families of maritime workers — including shipyard contractors, longshore workers, and others who aren't officially "seamen" — can now pursue wrongful-death claims in federal court when negligence, not just an unsafe vessel, causes a fatal injury on navigable waters. This closes a legal gap that previously let some fatal negligence claims go uncompensated under federal law even though survivable injuries from the same negligence would have been compensable.
What changes now
The case returns to the lower courts, where the shipyard can raise its remaining arguments about whether it actually owed a duty of care and whether it breached that duty — issues the trial court never reached because it had ruled no wrongful-death claim existed at all. The ruling is a final decision on the legal question of whether such a claim exists, not on whether this particular family will win.
What this does not decide
The Court assumed, for purposes of this appeal, that petitioner's negligence caused the death — it did not decide whether the shipyard actually owed a duty of care to Garris or breached one. Those factual and legal questions are left for the lower courts on remand.
Concurrences and dissents
Concurrence in part — Justice Ginsburg
Justice Ginsburg joined every part of the Court's opinion except the closing section, which suggested courts should generally defer further development of maritime wrongful-death law to Congress given its extensive legislation in the area. She argued that Moragne itself supports continued judicial development of maritime law working alongside Congress's statutes, not judicial restraint, so she declined to join that closing suggestion as unnecessary dictum.
How the Court got there
The legal reasoning, step by step
- The Court noted that maritime law already required two things: that negligence and unsafe-vessel conditions ('unseaworthiness') were both actionable wrongs, and that death caused by an unsafe vessel was compensable under the Court's 1970 decision in Moragne v. States Marine Lines, which had overruled a 19th-century rule barring maritime wrongful-death suits entirely.
- Because Moragne's facts involved only an unsafe vessel, the question of whether death caused by ordinary negligence was equally actionable had never been formally resolved, even though nothing in Moragne's reasoning singled out unseaworthiness as special.
- The Court found no principled reason to treat negligence differently from unseaworthiness: both are distinctly maritime duties, and allowing recovery for an injury but not the resulting death from the same negligent act produces an illogical result — one injured victim could recover while another who died from identical conduct could not.
- The Court then checked whether Congress's maritime statutes barred this extension. It concluded that the law covering sailors, the law covering deaths far offshore, and the workers' compensation law for other maritime employees each left room for the claim: none of them applied to this case or attempted to cut off this kind of lawsuit, and one provision expressly preserved claims against third parties like the shipyard.
- The Court acknowledged a general principle of restraint — that when Congress has heavily regulated an area, courts should often let Congress handle further changes — but concluded that recognizing this claim was not really a new development, since it merely applied a rule already established for unsafe-vessel deaths to the closely related duty of negligence.
Doctrinal impact
Cases affected by this decision
Reaffirms Moragne v. States Marine Lines, Inc. (398 U.S. 375)
The Court builds on Moragne's wrongful-death rule for unsafe vessels and extends the same rule to negligence.