Maritime Wrongful Death Lawyer in New Orleans: Help for Families After a Maritime Loss

The Young Firm is a New Orleans maritime law firm. Our practice is Jones Act and maritime injury law, and this page is written for families who have lost a spouse, parent, child, or partner in a vessel, river, offshore, or maritime workplace death in Louisiana and along the Gulf Coast.

You do not need to know which law applies before you call. You do not need to know whether your family member counted as a "seaman," whether the death happened in "state waters," or whether the paperwork the company sent you means anything. Those are legal questions to work through. What matters at the start is what you know: who your family member was, what they did for a living, where they were working, and what you have been told.

If you would rather talk than read, contact The Young Firm and describe what you know; a New Orleans maritime wrongful death lawyer can tell you what questions the facts raise. If you would rather read first, this page explains, in plain terms, what maritime wrongful-death claims can involve, why the answers depend on facts specific to your family member's job and the incident, and what you can protect now while you decide what to do next.

Can Our Family Pursue a Claim After a Maritime Death?

A wrongful-death claim is a civil claim brought after a death that the law attributes to someone else's negligence, an unsafe vessel, a defective product, or another legally recognized wrong. It addresses losses the law recognizes as belonging to the survivors — most commonly the financial support and services the family depended on. It is separate from any criminal case, and it is separate from a government safety investigation.

A maritime death may support one or more of the following: a negligence claim against the employer under the Jones Act (46 U.S.C. § 30104); a wrongful-death claim under general maritime law, the body of federal judge-made law recognized in Moragne v. States Marine Lines, 398 U.S. 375 (1970); a claim under the Death on the High Seas Act (46 U.S.C. chapter 303) for deaths caused by wrongful acts on the high seas; or death benefits under the Longshore and Harbor Workers' Compensation Act (33 U.S.C. § 909) for covered harbor workers. Which of these is actually available depends on the deceased person's work and vessel connection, where the incident occurred, who was responsible and in what role, and the family relationships involved. A maritime death does not by itself establish that anyone is legally liable.

The distinction that matters most at the outset is between two kinds of remedy:

• A civil liability claim. Jones Act, general maritime, and DOHSA claims require proof of a legally recognized basis for liability and proof that it caused the death. For a Jones Act claim, the basis is employer negligence. For an unseaworthiness claim, the basis is a vessel, crew, or equipment not reasonably fit for its intended use — a condition the vessel owner answers for whether or not the owner was negligent or knew about it. Product-defect claims against a manufacturer carry their own standards. What these claims share is that the loss alone is not enough; the family must be able to prove the basis for liability and the causal link.
• A benefits remedy. LHWCA death benefits for covered longshore and harbor workers do not require proof of employer fault, but they are paid on a statutory formula, and the statute limits what else can be recovered from the employer.

Some families have access to both types, through different parties. Some have access to one. The purpose of an initial review is to sort out which routes are realistically open.

For deeper treatment of the individual routes, see Jones Act wrongful-death claims, the Death on the High Seas Act, and LHWCA coverage and benefits.

Which Law Applies: Worker Status, Incident Location, and Worksite Matter

There is no single maritime wrongful-death statute. Congress and the courts built the framework piece by piece over more than a century, and the pieces overlap. Three sets of facts do most of the work in sorting out which remedies are available.

The deceased person's job and vessel connection. The Jones Act applies to "seamen" — workers whose duties contribute to the function of a vessel in navigation and who have a connection to a vessel or fleet that is substantial in both duration and nature. A deckhand, tankerman, engineer, or captain on a working vessel usually qualifies. A welder assigned to a shipyard, a longshoreman loading cargo from the dock, or a production operator on a fixed platform usually does not, though the line is contested often enough that the answer should never be assumed. Seaman status controls whether the family may sue the employer for negligence under the Jones Act, or is instead routed to LHWCA benefits, state workers' compensation, or another remedy. See who qualifies as a Jones Act seaman.

The legally relevant location of the incident. DOHSA applies when a death is caused by a wrongful act, neglect, or default occurring "on the high seas beyond 3 nautical miles from the shore of the United States" (46 U.S.C. § 30302). The statute looks to where the wrongful act and the incident occurred, not simply to where the person was eventually pronounced dead. Incidents in territorial waters — rivers, bays, the Intracoastal Waterway, coastal waters inside that line — are generally analyzed under general maritime law where maritime jurisdiction exists, and state law may also become relevant in some circumstances. Location matters, but maritime jurisdiction depends on the nature of the incident as well as the place. The distance in the statute is the statute's own measure, not a shorthand for every state or federal water boundary, and how it applies to a given incident is a legal question answered from the actual coordinates and sequence of events.

Whether the worksite was a vessel or a fixed structure. Jack-up rigs, drillships, liftboats, and supply vessels are generally treated as vessels, but vessel status depends on the structure's characteristics and the circumstances of its use, and it can be disputed. A production platform permanently fixed to the seabed on the Outer Continental Shelf is not a vessel. For fixed platforms, the Outer Continental Shelf Lands Act (43 U.S.C. § 1333) can adopt the law of the adjacent state — Louisiana, for most of the Gulf off our coast — as surrogate federal law. That means a death on a platform 40 miles offshore may be governed by rules that look very different from a death on a vessel anchored next to it. Distance alone does not settle the question.

The comparison below is an orientation tool, not an eligibility test. Routes overlap, exceptions exist, and families sometimes have claims in more than one category.

Three deliberately simplified hypotheticals show how the facts shift the analysis:

• River vessel. A deckhand on a towboat pushing barges on the Mississippi below New Orleans falls between barges during a coupling operation and dies. If he qualifies as a seaman, the potential routes are a Jones Act negligence claim against his employer and an unseaworthiness claim against the vessel owner, both under federal maritime law and regardless of where the family lives — but each depends on proving negligence or an unseaworthy condition that caused the fall.
• Offshore vessel. A galley hand on a supply vessel 60 miles south of Port Fourchon dies in an engine-room fire. If she qualifies as a seaman, Jones Act and unseaworthiness claims are potential routes, again subject to proof of negligence or an unseaworthy condition and causation. Because the incident occurred on the high seas, DOHSA questions also arise, and the interaction between these remedies affects what damages are recoverable.
• Fixed platform. A contract mechanic on a production platform in federal waters dies in a crane incident. He is likely not a seaman. OCSLA likely governs, potentially borrowing Louisiana law, and the claims may run against the platform operator, the crane contractor, or an equipment manufacturer rather than his own employer.

Each of these examples hides a dozen factual questions that change the answer. Offshore and vessel-specific scenarios are examined in more depth on offshore wrongful-death claims and fatal vessel, tugboat, and barge accidents.

Contacting a Lawyer, Filing the Claim, and Receiving Compensation Are Different Questions

Families often assume that only the "official" representative can ask a lawyer anything, and that anyone who was close to the deceased person will automatically share in whatever is recovered. Neither assumption is right, and separating three questions avoids a lot of confusion.

Who can ask for a review? Anyone. A spouse, an adult child, a parent, a sibling, a partner who was never married to the deceased, or a friend helping the family can contact a maritime wrongful death attorney and describe what happened. Asking questions does not require legal authority, an appointed representative, or a death certificate.

Who has authority to file? Under the Jones Act and DOHSA, the civil action is brought by the deceased person's personal representative — the person appointed by a court to act for the estate, sometimes called an executor or administrator, or in Louisiana, a succession representative. The representative sues on behalf of the beneficiaries; the representative does not personally own the recovery. If no representative has been appointed, that is a procedural step to be addressed, not a reason to delay asking questions. LHWCA death benefits work differently: eligible survivors claim the benefits directly.

Who may receive compensation? The statutory beneficiaries are the family members the applicable law designates. The Jones Act incorporates the beneficiary provisions of the Federal Employers' Liability Act (45 U.S.C. § 51), which organize eligible relatives in a structured order. DOHSA (46 U.S.C. § 30302) recognizes a spouse, parent, child, or dependent relative. The LHWCA (33 U.S.C. § 909) sets out its own categories and dependency requirements. These lists are not the same, and a relationship that qualifies under one remedy may not qualify under another.

This is why family relationship alone does not settle eligibility. Spouses, children, parents, unmarried partners, stepchildren, and other dependents are relationships that require review under the specific remedy that applies — not categories that are automatically included or excluded. An unmarried partner, for example, faces real obstacles under some of these statutes and may have a path under others depending on dependency and the governing law.

Incomplete estate paperwork should not stop you from asking questions. Beneficiary hierarchies, appointment procedure, and questions involving minor children or extended family are addressed on family rights after a maritime death and the remedy-specific pages for Jones Act wrongful-death claims and the Death on the High Seas Act.

What Compensation May Be Available—and Why the Remedy Limits Recovery

This is where families are most often misled, sometimes by well-meaning people. General wrongful-death checklists promise lost earnings, loss of companionship, grief, and punitive damages as if every case carried all of them. Maritime law does not work that way. What can be recovered depends on which remedy applies and who the claimant is.

Pecuniary loss is the core of most maritime death recoveries. In ordinary language, it is the measurable financial value the deceased person would have provided to the beneficiaries: the share of earnings that would have supported the household, the value of services around the home, and in some contexts the value of guidance and care to minor children expressed in economic terms. The Jones Act, through FELA, and DOHSA (46 U.S.C. § 30303) both frame recovery around this kind of loss.

Nonpecuniary loss — loss of society, companionship, grief, mental anguish — is where the remedies diverge sharply. In Miles v. Apex Marine Corp., the Supreme Court held that the family of a seaman cannot recover loss of society under general maritime law, reasoning that the Jones Act's pecuniary-loss limits should govern uniformly. DOHSA expressly limits recovery to pecuniary loss, with a narrow exception for certain commercial aviation deaths (46 U.S.C. § 30307) that does not apply to vessel or platform deaths. Yamaha left room for state-law nonpecuniary damages in some nonseafarer deaths in territorial waters — passengers and recreational boaters, not seamen, and not clearly other maritime workers. Whether your family falls within one of the narrower openings is a legal question answered from the facts.

Survival claims are different from wrongful-death claims. A wrongful-death claim addresses the survivors' own losses. A survival claim continues the claim the deceased person could have brought for what they suffered before death — conscious pain and suffering, medical expenses, lost wages between injury and death — pursued through the authorized representative. Who may pursue a survival claim and who receives its proceeds depend on the governing law: the FELA survival provision incorporated into the Jones Act directs recovery to statutory beneficiaries, while other applicable survival laws may provide recovery through the estate. Whether a survival claim exists, and what it may include, depends heavily on the remedy: FELA § 59, incorporated into the Jones Act, provides one; Dooley v. Korean Air Lines, 524 U.S. 116 (1998), held that DOHSA leaves no room for a general maritime survival recovery for pre-death suffering. Survival recovery is never automatic, and a death that was instantaneous may leave nothing to recover under this heading. The detailed limits are on maritime survival actions.

The following overview is an orientation, not a menu. Every entry carries qualifications that depend on the claimant, the defendant, and the governing law.

Two cautions. First, a settlement average or range cannot honestly be quoted before the remedy, the earnings history, the family structure, and the strength of the liability case are known. Second, categories cannot be stacked. Lost support recovered by the beneficiaries and lost earnings claimed through a survival action cannot both compensate the same dollars, and courts police that overlap.

Detailed damages rules for each route are on Jones Act wrongful-death claims, the Death on the High Seas Act, and, for benefit calculations, LHWCA benefits and compensation.

Does the Claim Involve an Employer, Vessel Owner, Contractor, or Equipment Manufacturer?

After a workplace death, the first company to reach out is usually the employer, and the first payment is usually from the employer or its insurer. Families sometimes take that as the whole of the matter. It often is not.

Maritime workplaces involve layered relationships. A deckhand may be employed by a crewing company, working aboard a vessel owned by a second company and chartered by a third, moving cargo for a fourth, using a winch manufactured by a fifth. Offshore, a single platform can have an operator, a drilling contractor, a lift-boat company, a catering contractor, and several service companies on location at once. Each entity's potential responsibility depends on its role, and the same facts can support different theories against different parties:

• Negligence — a failure to use reasonable care, whether by the employer (Jones Act), a vessel operator, a contractor, or a platform operator.
• Vessel condition — the unseaworthiness doctrine, under which a vessel owner owes seamen a vessel, crew, and equipment reasonably fit for their intended use. Liability does not depend on the owner's knowledge of the defect. See unseaworthiness claims.
• Product defects — claims against the manufacturer of a crane, winch, hose, valve, or piece of safety equipment that failed.
• Statutory benefits — LHWCA death benefits, which are owed by the employer without regard to fault.

None of these entities is a defendant simply because it was present. Identifying who is worth investigating requires the employment records, the vessel documentation, the charter and service contracts, and the incident facts.

The interaction between benefits and civil claims also needs care. Under 33 U.S.C. § 905(a), LHWCA benefits are the exclusive remedy against a covered worker's employer, but § 905(b) preserves a negligence claim against the vessel, and § 933 preserves claims against other third parties. Section 933 also imposes consequences: settling a third-party claim without the employer's or carrier's written approval, on terms that do not meet statutory requirements, can forfeit benefits, and benefits already paid create reimbursement and credit issues against any third-party recovery. Similar coordination questions arise when a Jones Act employer has paid maintenance and cure or other sums and a third party is also at fault.

The practical point is this: receiving a check, or a sympathetic explanation, from one company does not tell you whether another remedy exists. Detailed treatment of non-employer liability is on claims against responsible third parties and third-party claims alongside Jones Act and LHWCA remedies.

How Long Do We Have—and What If a Vessel Owner Sends Court Papers?

There is no single deadline for maritime death claims. Anyone who tells you "you have three years, so there is no hurry" is giving you half of one answer to a question that has several.

Civil claims for maritime torts. Under 46 U.S.C. § 30106, a civil action for damages for personal injury or death arising out of a maritime tort must be brought within three years after the cause of action arose, "except as otherwise provided by law." The Jones Act, through FELA, carries its own three-year period. This is the general framework for Jones Act, general maritime, and DOHSA claims against private defendants. It does not govern everything.

Benefits claims. The LHWCA has its own notice requirement and its own claim-filing period — ordinarily one year for a death claim — and both run from trigger points and carry exceptions that differ from the maritime tort statute. Missing them can affect benefits. See LHWCA filing deadlines.

Government defendants and state-law claims. Deaths involving government-owned or government-operated vessels, or claims that borrow state law through OCSLA or Yamaha, can carry shorter periods and administrative prerequisites. These require individualized analysis; they are not listed here because a wrong number is worse than none.

Court-ordered response dates. This is the one families most often miss. After a serious vessel casualty, a vessel owner may file a limitation-of-liability action in federal court under Supplemental Admiralty Rule F, seeking to cap its exposure at the value of the vessel and pending freight. The court then issues a notice requiring everyone with a claim to file it in that proceeding by a date the court sets — often a matter of months — and typically enjoins related lawsuits elsewhere. A family that does not file by the court's deadline can be defaulted and lose the claim, regardless of the three-year statute. If you receive anything from a federal court, or anything that mentions "limitation," "exoneration," or "monition," keep the envelope, the notice, and every attachment together, and have a maritime attorney review them promptly.

Nothing pauses these clocks on its own. A consultation does not. Negotiating with the insurer does not. Waiting for the Coast Guard to finish does not. Fuller deadline analysis for individual remedies is on Jones Act deadlines, LHWCA filing deadlines, and family rights after a maritime death.

What to Keep—and Why You Need Not Wait for the Coast Guard Investigation

A government investigation and a civil claim are different things with different purposes. The Coast Guard investigates marine casualties to determine cause and improve safety; the National Transportation Safety Board does the same for certain major casualties. Neither exists to compensate your family, neither runs on your family's timeline, and neither produces a report your lawyer can simply hand to a jury. Under 46 U.S.C. § 6308, Coast Guard marine casualty investigation reports, including their conclusions about fault, are generally not admissible as evidence in civil proceedings. The underlying facts — what witnesses saw, what the vessel's records show, what the equipment looked like — are what a civil case is built on, and those facts do not wait for a report to be published.

You are not being asked to investigate the death yourself. You are being asked to hold on to what you already have and not to give anything away before you understand it.

Materials the family may already have or can gather without difficulty:

• Communications from the employer, the vessel owner, or their insurers, including letters, emails, texts, and voicemails
• Pay stubs, W-2s, employment contracts, crew assignments, or offshore schedules showing earnings and work history
• Benefits paperwork of any kind — life insurance, workers' compensation, LHWCA, union, or employer death benefits
• Photographs or messages your family member sent from the vessel or worksite, including anything about conditions, equipment, or fatigue
• Names and contact details of crewmates, coworkers, or anyone who has reached out to you about what happened
• Any court papers, agency letters, or documents someone asked you to sign
• Funeral and related expense records

Materials counsel typically moves to preserve or obtain through legal process:

• Vessel logs, voyage data, electronic charting and engine data, and bridge or deck recordings
• Maintenance, inspection, and repair records for the vessel and the equipment involved
• Job safety analyses, work permits, standing orders, and the actual instructions given for the task
• Crew lists, hours-of-work records, training and certification files
• Contracts and charter agreements identifying the companies involved
• Internal incident reports, photographs, and communications generated after the death

Do not try to board the vessel, enter a restricted worksite, or obtain records through anyone who is not authorized to give them to you. Do not alter, annotate, or discard originals; make copies if you need to organize them.

Two specific cautions. If an insurer or company representative asks you to sign a release, a settlement, or a document you do not fully understand, have it reviewed first — a release can extinguish claims you do not yet know you have. If you are asked to give a recorded statement to an insurer, you are entitled to consult a lawyer before doing so. This is not advice to withhold information the law requires you to provide; it is advice to understand what you are being asked and why before you commit words to a recording that may later be used against the claim.

Extended guidance on family procedure is on family rights after a maritime death. Vessel-specific evidence questions — what a towboat's records show, how a barge fleeting incident is reconstructed — are on fatal vessel, tugboat, and barge accidents.

What Evaluating a Maritime Death Claim Involves

Evaluating a maritime death is not a matter of filling in a wrongful-death template. It is a sequence of questions, each of which narrows or widens the next.

The worker's status and connection to a vessel. Job duties, the time spent aboard, the nature of the work, and the ownership and operation of the vessel or fleet determine whether the Jones Act and unseaworthiness routes are available or whether the family is routed to LHWCA, OCSLA, or another framework. This step decides which court, which defendants, and which damages rules are even in play.

The legally relevant location and worksite. Coordinates, the nature of the structure, and the incident sequence determine whether DOHSA, general maritime law, OCSLA-borrowed state law, or a combination governs. None of this is inferred from the family's residence, the employer's headquarters, or the port the vessel left from.

The beneficiaries and the representative. Family relationships are mapped against the beneficiary provisions of the applicable remedy, and the question of whether a personal representative has been or must be appointed is answered early.

Evidence. Preservation demands to the vessel owner, employer, and other companies; requests for records through the appropriate process; witness identification while memories are fresh. This work proceeds alongside any ongoing Coast Guard or NTSB investigation rather than waiting for it, because the civil case depends on underlying facts rather than the agency's conclusions.

Every potentially responsible entity. Employment records, vessel documentation, charters, and service contracts show who was actually in control of the vessel, the task, and the equipment. This step frequently changes the shape of the case.

Damages under the governing remedy. Earnings history, benefits, household contributions, and the family's dependency are analyzed against the pecuniary-loss framework that applies — what the law allows and what it does not — before any decision about filing or settlement.

Throughout, several processes run at the same time: the agency investigation, estate or succession administration, any benefits claim, communications with insurers, and civil litigation. They involve different people, and confusing one for another is how deadlines are missed and rights are lost.

The Young Firm practices from New Orleans, in a region where maritime death cases arise from the Mississippi River and its fleeting areas, the Intracoastal Waterway, the ports and shipyards along the coast, and the Gulf of Mexico offshore. That regional grounding is part of the firm's practice, but jurisdiction and governing law are determined by the incident, not by where any of us live. More about the firm, its attorneys, and its broader maritime practice is on the firm homepage.

Ask About Your Family's Options, Even If You Do Not Have All the Records

Families often delay calling a Louisiana maritime wrongful death lawyer because they believe they need to have everything organized first — a death certificate, the accident report, an appointed representative, a complete file. You do not. An initial conversation works from what you know.

What helps most at the start:

• Your family member's name, age, and job — what they actually did aboard or at the site
• The employer and, if known, the name and owner of the vessel or facility
• The date and place of the death, as specifically as you can
• Your relationship to the deceased, and who else in the family depended on them
• Anything you have received: letters from the company or insurers, benefits paperwork, court notices, documents you were asked to sign
• Whether anyone has asked you for a statement or offered you a payment

The first conversation is about understanding what happened and identifying the questions that need answers. It is not a commitment on your part and does not, by itself, create an attorney-client relationship. Ask directly about fees, how case expenses are handled, what happens if there is no recovery, and who will communicate with your family; you should never be uncertain about the terms before you agree to anything.

If you are reading this on behalf of a spouse, parent, or sibling who is not ready to make calls, you can make the first contact and relay what you learn. If you have already received papers from a court or a vessel owner, mention that at the outset so they can be reviewed for deadlines.

Contact The Young Firm to describe your situation and ask what a maritime wrongful death attorney would need to know. Expect a candid account of what the facts show, what is not yet known, and what the next step would be.

Legal Authorities Referenced in This Guide

This guide is general legal information about maritime wrongful-death claims. It does not decide any individual family's rights, which depend on facts this page cannot know. Every substantive statement above is qualified by the remedy it addresses, and those qualifications are part of the answer, not footnotes to it.

The principal authorities referenced, and the proposition each supports:

Statutes and rules

• Jones Act, 46 U.S.C. § 30104 — A seaman injured in the course of employment, or the personal representative of a seaman who dies, may bring a negligence action against the employer, with the incorporated Federal Employers' Liability Act governing the details.
• Federal Employers' Liability Act, 45 U.S.C. §§ 51, 56, 59 — Beneficiary provisions, the three-year limitations period, and survival of the deceased person's own claim, all incorporated into the Jones Act.
• Death on the High Seas Act, 46 U.S.C. §§ 30301–30308 — Wrongful-death remedy for deaths caused by wrongful acts occurring on the high seas beyond 3 nautical miles from shore, brought by the personal representative for the spouse, parent, child, or dependent relative; recovery limited to pecuniary loss, with a distinct commercial-aviation provision and a savings clause for state-water deaths.
• 46 U.S.C. § 30106 — A civil action for damages for personal injury or death arising out of a maritime tort must be brought within three years after the cause of action arose, except as otherwise provided by law. This is the general limitations framework for Jones Act, general maritime, and DOHSA claims against private defendants; it does not displace shorter or differently structured periods that other statutes impose.
• 46 U.S.C. § 6308 — Coast Guard marine casualty investigation reports, including their findings and conclusions about fault, are generally not admissible as evidence in civil proceedings. The civil case rests on the underlying facts, not the agency's report.
• Longshore and Harbor Workers' Compensation Act, 33 U.S.C. § 905(a)–(b) — Compensation benefits are the exclusive remedy against a covered worker's employer, but a negligence claim against the vessel is preserved.
• 33 U.S.C. § 909 — Death benefits for eligible survivors of covered workers, paid without regard to fault as a percentage of average weekly wage on a statutory schedule, with reasonable funeral expenses up to a statutory cap; the statute sets its own survivor categories and dependency requirements.
• 33 U.S.C. §§ 912–913 — Notice of injury or death and claim-filing requirements for LHWCA benefits, including the ordinary one-year period for a death claim, subject to trigger rules and exceptions.
• 33 U.S.C. § 933 — Preserves claims against third parties other than the employer; conditions the effect of third-party settlements on written approval by the employer or carrier; and creates reimbursement and credit consequences for benefits already paid.
• Outer Continental Shelf Lands Act, 43 U.S.C. § 1333 — Extends federal law to fixed structures on the Outer Continental Shelf and adopts the law of the adjacent state as surrogate federal law to the extent it is applicable and not inconsistent with federal law; the mechanism by which Louisiana law may govern a death on a fixed platform off the Louisiana coast.
• Supplemental Rule F, Federal Rules of Civil Procedure (Supplemental Rules for Admiralty or Maritime Claims) — Procedure for a vessel owner's limitation-of-liability action, under which the court issues notice requiring all claims to be filed in the proceeding by a court-set date and typically enjoins related suits elsewhere; failure to file by that date can result in default.

Court decisions

• ***Moragne v. States Marine Lines, Inc.*, 398 U.S. 375 (1970)** — Recognized a wrongful-death action under general maritime law, the federal judge-made law that governs many maritime deaths in territorial waters.
• ***Miles v. Apex Marine Corp.*, 498 U.S. 19 (1990)** — The family of a seaman cannot recover loss of society under general maritime law; the Jones Act's pecuniary-loss framework governs uniformly. The source of the uniformity principle that also bears on the availability of punitive damages in seaman death claims.
• ***Yamaha Motor Corp. v. Calhoun*, 516 U.S. 199 (1996)** — State wrongful-death remedies may supplement general maritime law for the death of a nonseafarer in territorial waters; the decision addressed a recreational boater and did not extend the same result to seamen or clearly to other maritime workers.
• ***Dooley v. Korean Air Lines Co.*, 524 U.S. 116 (1998)** — Where DOHSA applies, it leaves no room for a general maritime survival claim for the deceased person's pre-death pain and suffering.