Massachusetts Injury Lawyers Blog
Workplace fatalities occurring on or near navigable waters often raise complex questions about which legal remedies are available to surviving family members. In maritime settings, those questions frequently intersect with workers’ compensation statutes and federal maritime law, creating uncertainty about whether negligence claims may proceed alongside statutory benefit schemes. A recent decision directly addressed this issue, clarifying the scope of wrongful death remedies under general maritime law and how they coexist with maritime workers’ compensation frameworks. If you have questions about work-related injuries or fatalities in maritime settings, you should consider speaking with a Massachusetts workers’ compensation attorney to better understand your legal options.
Case Setting
Allegedly, the decedent was employed by a subcontractor performing sandblasting work aboard a vessel docked in navigable waters of the United States. While carrying out assigned duties, the decedent sustained serious injuries aboard the vessel and died the following day as a result of those injuries.
It is alleged that the work was performed under a layered subcontracting arrangement involving multiple entities, including the defendant shipbuilding company. The plaintiff, acting as the personal representative of the estate, asserted that the fatal injuries were caused by negligent conduct attributable to the defendant and another subcontractor involved in the work.
Reportedly, the plaintiff filed suit in federal court invoking admiralty jurisdiction and seeking damages under general maritime law for wrongful death based on negligence. The complaint also asserted claims under state wrongful death law. The district court dismissed the maritime claim, concluding that general maritime law did not recognize a cause of action for wrongful death resulting from negligence in state territorial waters.
It is reported that the plaintiff appealed, and the federal court of appeals reversed the dismissal. The court reasoned that existing precedent supported recognition of a maritime wrongful death action based on negligence. The defendant sought further review.
Workers’ Compensation and Wrongful Death Claims
The court reviewed whether a negligent breach of a general maritime duty of care is actionable when it results in death, just as it is when it results in injury. The Court grounded its analysis in longstanding principles of general maritime law and prior decisions addressing wrongful death remedies.
The Court relied heavily on its earlier decision recognizing a maritime wrongful death cause of action arising from violations of maritime duties. Although that earlier case involved unseaworthiness, the Court explained that negligence is equally a maritime duty and that no rational basis exists for treating death caused by negligence differently from death caused by unseaworthiness. The Court emphasized that maritime law has long recognized negligence claims for personal injury and that denying recovery solely because the injury proved fatal would create unjust and anomalous results.
The Court also examined whether federal statutes governing maritime injuries and workers’ compensation displaced a general maritime negligence remedy. It concluded that none of the relevant statutes barred such claims. The Jones Act was found inapplicable because it applies only to seamen. The Death on the High Seas Act did not apply because the death occurred in state territorial waters. The Longshore and Harbor Workers’ Compensation Act provided workers’ compensation benefits and certain negligence remedies but expressly preserved claims against third parties, which included the defendant.
The Court rejected the argument that maritime workers’ compensation schemes reflected a congressional intent to preclude wrongful death negligence claims under general maritime law. Instead, the Court held that recognizing such claims was consistent with statutory policy and necessary to preserve uniformity in maritime remedies. The judgment of the court of appeals was affirmed, confirming the availability of a maritime wrongful death action based on negligence.
Consult a Skilled Massachusetts Workers’ Compensation Attorney
If you have questions about workers’ compensation benefits or wrongful death claims arising from a maritime workplace incident, it is in your best interest to talk to an attorney. James K. Meehan of the Law Office of James K. Meehan is a skilled Massachusetts workers’ compensation attorney who assists clients throughout Massachusetts with work-related injury and death claims, including matters involving maritime employment and third-party liability. You can reach him at 508-822-6600 or submit a request through the firm’s online contact form to arrange a consultation and discuss your legal options.