## Facts

- James Rock sued the Panama Railroad Company in the District Court for the Canal Zone seeking damages for the death of his wife.
- Rock alleged his wife died in 1918 while riding as a passenger on the railroad’s train due to the railroad’s negligence.
- The claim relied on Article 2341 of the Civil Code of Panama, continued in force in the Canal Zone by Executive Order (1904) and confirmed by Congress (1912).
- Article 2341 broadly required a person who commits a fault causing damage to “repair” the damage.

## Issues

1. Whether Article 2341, as in force in the Canal Zone, created a private right of action for wrongful death caused by negligence.
2. Whether foreign judicial interpretations of analogous civil-code provisions should be treated as incorporated into Article 2341 as applied in the Canal Zone.

## Decision

- The Supreme Court reversed the judgment for Rock.
- The Court held that Article 2341 did not create a wrongful-death cause of action for negligence in the Canal Zone.
- The Court concluded the article should be construed in line with the common-law rule that no civil action lies for death absent explicit legislative authorization.

## Legal Principles

- At common law, no private cause of action arises from the death of a human being; wrongful-death recovery depends on statutory authority.
- When a civil-code provision from another legal system is applied in a U.S.-controlled territory without a clear, settled, and contemporaneous authoritative construction in the originating jurisdictions, U.S. courts may construe it independently, giving foreign decisions only persuasive weight.
- A general delict provision requiring reparation for “damage” caused by fault will not be read to authorize wrongful-death actions absent clear legislative direction, particularly where local interpretive practice follows common-law principles.

## Conclusion

The Court held that the Canal Zone’s adoption and continuation of Article 2341 did not supply a statutory wrongful-death remedy for negligence, so the plaintiff lacked a right of action and the prior judgments for damages could not stand.


Panama R.R. Co. v. Rock, 266 U.S. 209 (1924)