## Facts

- Heli Ramon Sanchez worked as a seaman for Loffland Brothers Company on a vessel operating on Lake Maracaibo, Venezuela.
- Sanchez died on February 3, 1974, in the course of his employment.
- On July 27, 1977, more than three years after the death, Sanchez’s widow sued in federal district court.
- The complaint asserted wrongful-death claims under the Jones Act and under general maritime law (a Moragne-type wrongful-death action).
- Loffland Brothers moved for summary judgment, asserting the claims were barred by limitations; the widow argued the general maritime claim survived and, alternatively, that equitable estoppel prevented the limitations defense.

## Issues

1. Whether a general maritime law wrongful-death claim may proceed after the limitations periods applicable to analogous statutory wrongful-death remedies (Jones Act and DOHSA) have expired.
2. Whether the record created a genuine issue of material fact that the employer should be equitably estopped from asserting a statute-of-limitations defense.

## Decision

- The Fifth Circuit affirmed summary judgment for Loffland Brothers.
- A Moragne-type general maritime wrongful-death claim was barred when brought after the limitations periods governing the analogous statutory maritime wrongful-death remedies.
- The record did not support equitable estoppel; no genuine issue of material fact precluded summary judgment on the limitations defense.

## Legal Principles

- When Congress has provided a statutory scheme for maritime wrongful death, courts completing or applying related judge-made maritime remedies must respect the statutory framework rather than permit parallel rules that conflict with it.
- A general maritime wrongful-death action may not be used to evade or extend congressionally selected limitations periods applicable to analogous statutory maritime wrongful-death causes of action (including the Jones Act and DOHSA).
- Equitable estoppel against a limitations defense requires evidence of misleading conduct (such as misrepresentation or concealment) that reasonably caused delayed filing; unsupported allegations are insufficient to defeat summary judgment.

## Conclusion

The court held that the widow’s general maritime wrongful-death claim could not function as a time-extension device beyond the limitations periods associated with the Jones Act and DOHSA and that, absent evidence of misleading conduct, equitable estoppel did not bar the employer’s limitations defense.


Sanchez v. Loffland Bros. Co., 626 F.2d 1228 (5th Cir. 1980)