Law School Case Brief
Sea-Land Servs. v. Gaudet - 414 U.S. 573, 94 S. Ct. 806 (1974)
Recovery for loss of support has been universally recognized, and includes all the financial contributions that the decedent would have made to his dependents had he lived. The overwhelming majority of state wrongful-death acts and courts interpreting the Death on the High Seas Act, 46 U.S.C.S. §§ 761-768, have permitted recovery for the monetary value of services the decedent provided and would have continued to provide but for his wrongful death. Such services include the nurture, training, education, and guidance that a child would have received had not the parent been wrongfully killed. Services the decedent performed at home or for his spouse are also compensable.
A longshoreman who suffered injuries while working aboard a vessel in Louisiana navigable waters recovered damages for his disability, pain and suffering, and loss of earnings in an action against the vessel owner based on unseaworthiness. The longshoreman died shortly thereafter and his widow filed a wrongful death action against the vessel owner, a corporation, based on unseaworthiness. The district court dismissed the widow's suit on grounds of res judicata and failure to state a claim. On appeal, the United States Court of Appeals for the Fifth Circuit reversed. It determined that the wife had a compensable cause of action for her husband's death wholly apart from and not extinguishable by the latter's recovery of his personal injuries. The vessel owner challenged the order by the United States Court of Appeals for the Fifth Circuit allowing the wife to maintain the action after the decedent had recovered damages in his lifetime.
Was the wife barred from recovering damages?
The United States Supreme Court affirmed. The Court held that: (1) the maritime wrongful death action based on unseaworthiness could be maintained under federal maritime law even though the decedent, prior to his death, had recovered from the vessel owner in the personal injury action, the wrongful death remedy involved a different cause of action than the decedent's personal injury action, and was not precluded by res judicata; (2) under the maritime wrongful death remedy, the decedent's dependents could recover damages for their loss of support, services, and society, as well as for funeral expenses; and (3) the doctrine of collateral estoppel precluded recovery in the death action of damages for loss of support insofar as such damages overlapped the decedent's prior recovery in his personal injury action for loss of future wages, as to which the decedent acted in a fiduciary capacity to the extent that he represented his dependents' interest in such portion of his earnings which, but for his wrongful death, they had a reasonable expectation of him providing for their support.
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