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Yamaha Motor Corp., U.S.A. v. Calhoun

Supreme Court of the United States · 1996 · Civil Procedure

Civil ProcedureAdmiraltyWrongful DeathInterlocutory Appealsadmiralty jurisdictionmaritime wrongful deathterritorial watersnonseafarers

Facts

Twelve-year-old Natalie Calhoun died while riding a Yamaha WaveJammer jet ski in the waters off a Puerto Rico resort. Her parents sued Yamaha in federal court, alleging the jet ski was defectively designed or made and invoking Pennsylvania wrongful-death and survival statutes. They asserted negligence, strict liability, and breach of implied warranties, and sought various damages including loss-related and punitive damages. Yamaha argued that because the death occurred on navigable waters, federal maritime law supplied the exclusive remedy and displaced state law.

Issue

Whether the federal maritime wrongful-death action recognized in Moragne v. States Marine Lines supplies the exclusive remedy for the death of a nonseafarer in territorial waters, thereby displacing otherwise applicable state wrongful-death and survival statutes. Also, whether a court of appeals reviewing a § 1292(b) certification may address issues fairly included within the certified order even if not specified in the district court's stated question.

Rule

In maritime accident cases involving the death of a nonseafarer in territorial waters, where no federal statute specifies the appropriate relief, state wrongful-death and survival remedies remain available and are not displaced by Moragne's general maritime wrongful-death action. For interlocutory appeals under 28 U.S.C. § 1292(b), appellate jurisdiction runs to the certified order itself, and the court of appeals may address any issue fairly included within that order.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Maya Ortiz, a vacationing schoolteacher from Ohio, died when a rented parasail harness allegedly failed just off the coast of Key West, Florida. Her parents sued the harness manufacturer in federal court, invoking admiralty jurisdiction and Florida wrongful-death and survival statutes, and seeking loss-of-society and punitive damages.

If no federal statute specifically prescribes the remedy for Maya's death, which is the strongest argument about the available remedies?

Explanation. The majority held that in maritime wrongful-death cases involving nonseafarers killed in territorial waters, state wrongful-death and survival remedies remain applicable unless a federal statute prescribes otherwise. Admiralty jurisdiction alone does not automatically displace state law, and Moragne did not create an exclusive federal damages regime for such deaths.