## Facts

- Awtrey Gaudet, a longshoreman, suffered severe injuries aboard Sea-Land’s vessel in Louisiana navigable waters.
- Gaudet sued Sea-Land in federal court for unseaworthiness and obtained a judgment for past and future wages, pain and suffering, and medical and incidental expenses.
- About ten days after judgment, Gaudet died; Sea-Land paid the judgment to his estate.
- Gaudet’s widow, Helen Gaudet, filed a general maritime wrongful-death action seeking her own damages from his death, including loss of support, services, and society, plus funeral expenses.

## Issues

1. Whether the decedent’s lifetime recovery in a maritime personal-injury action bars a dependent’s later maritime wrongful-death action under res judicata.
2. Whether the general maritime wrongful-death action permits recovery for loss of support, loss of services, loss of society, and funeral expenses.
3. How to prevent double recovery where the decedent previously recovered damages tied to future earnings and dependents later seek loss-of-support damages.

## Decision

- The Supreme Court affirmed the Fifth Circuit in a 5–4 decision.
- The widow’s general maritime wrongful-death claim was not barred by the decedent’s prior personal-injury judgment because it was a separate cause of action arising upon death and belonging to the dependent.
- The general maritime wrongful-death remedy permits recovery for loss of support, loss of services, loss of society, and funeral expenses.
- Any overlap between the decedent’s prior recovery for future wages and the dependent’s loss-of-support claim is addressed through collateral estoppel to avoid double payment, not by barring the wrongful-death action.

## Legal Principles

- A general maritime wrongful-death action is based on the death itself and is independent of the decedent’s personal-injury action.
- Res judicata does not bar a dependent’s wrongful-death claim when the claim had not accrued at the time of the decedent’s personal-injury judgment and compensates the dependent’s own losses.
- Recoverable damages under the general maritime wrongful-death action include loss of support, loss of services, loss of society (care, comfort, and companionship), and funeral expenses.
- Potential duplication between previously awarded future-wage damages and later loss-of-support damages is controlled by issue preclusion (collateral estoppel) to the extent factual determinations in the first case resolve the economic-loss component.

## Conclusion

The Court held that a dependent’s maritime wrongful-death action is a distinct claim that survives a decedent’s prior recovery for personal injury and that the maritime remedy allows broad compensatory damages, with collateral estoppel used to prevent double recovery for overlapping economic losses.


Sea-Land Servs., Inc. v. Gaudet, 414 U.S. 573 (1974)