## Facts

- Christopher Garris performed sandblasting work aboard a vessel berthed in navigable waters while the vessel was under the control of Norfolk Shipbuilding & Drydock Corporation.
- Garris was injured during the work and later died from his injuries.
- The administratrix of Garris’s estate filed a federal admiralty action seeking wrongful-death damages under general maritime law, alleging that negligence caused Garris’s death.
- The complaint did not invoke a specific federal wrongful-death statute.

## Issues

1. Whether general maritime law provides a wrongful-death cause of action for death resulting from the negligent breach of a maritime duty of care.
2. Whether recognizing such an action is inconsistent with federal statutory schemes addressing maritime injury and death (including the Jones Act, DOHSA, and the LHWCA).

## Decision

- The Supreme Court affirmed the Fourth Circuit.
- The Court held that the general maritime wrongful-death action recognized in *Moragne* is available for negligent breach of a maritime duty of care.
- The Court rejected a rule that would allow wrongful-death recovery for unseaworthiness but not for negligence.
- The Court concluded that recognizing the negligence-based claim was consistent with Congress’s maritime statutes because the claim was an application of established maritime negligence principles within the *Moragne* framework.
- The case could proceed on a general maritime wrongful-death theory based on negligence.

## Legal Principles

- General maritime law recognizes a wrongful-death cause of action for death caused by violation of maritime duties, including negligence.
- There is no rational basis, for general maritime wrongful-death purposes, to distinguish negligence from unseaworthiness when both are maritime duties.
- Judicial development of general maritime law must account for congressional enactments in the field, but applying the *Moragne* wrongful-death action to negligence does not improperly conflict with statutory regimes such as the Jones Act, DOHSA, or the LHWCA.

## Conclusion

The Supreme Court held that a wrongful-death action under general maritime law extends to deaths caused by negligent breach of a maritime duty of care, allowing the estate’s admiralty negligence claim to go forward notwithstanding the absence of an expressly applicable federal wrongful-death statute.


Norfolk Shipbuilding & Drydock Corp. v. Garris, 532 U.S. 811 (2001)