Yamaha Motor Corp v Calhoun case brief summary
Supreme Court, 1996
- A 12 year old girl died while using a jet ski in Puerto Rico.
- The girl collided with a vessel anchored in the waters off the hotel frontage.
- The Calhouns sued Yamaha.
- They sued on negligence, breach of warranty, strict product liability and wanted state law to apply.
Whether state remedies can supplement general maritime law (as they did before Moragne)
- Because this case involves a watercraft collision on navigable waters, it falls within the admiralty’s domain.
- Maritime policies demanded uniform adherence to a federal rule of decision with no leeway for variation or supplementation by state law.
- Moragne centered on the extension of relief, not on the contraction of remedies.
- The court preserves the application of state statutes to deaths within territorial waters.
- Damages available for the jet-ski death are properly governed by state law.
- This is not a seafarer death. With seafarer there are many restrictions to recover than for non-seafarer.
For Non seafarers where you die is important, if in territorial waters, the Yamaha case will apply and state statutes will apply, if in high seas DOHSA will apply.
Note on Developments in the Calhoun Case
Again on interlocutory appeal, the Third Circuit revised the district court’s formulation into a three way depacage:
- Liability would be set by maritime law.
- Compensatory damages would be set by an unusual Pennsylvania law. The survival damages include a decedent’s loss of earning capacity or potential, less personal maintenance, from the time of death through the decedent’s estimated lifetime employment period.
- Punitive damages would be set up by Puerto Rican law, which provides no relief.
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