Sea-Land Services, Inc. v. Gaudet
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Seven confirmed adverse treatments are listed below, including the Supreme Court's recognition that the 1972 LHWCA amendments rendered Gaudet inapplicable on its original facts for later claims. Mobil Oil Corp. v. Higginbotham confined its broadly worded damages rule to coastal waters, and Miles v. Apex Marine Corp. confined it to longshoremen rather than Jones Act seamen. One citing opinion lacks a usable Gaudet passage, so this record cannot make a complete good-law assessment.
648 later cases cite Sea-Land Services, Inc. v. Gaudet; 75 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Sea-Land Services, Inc. v. Gaudet?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Superseded by statute
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The Court recognized that the 1972 LHWCA amendments, enacted after the underlying suit was filed, made Gaudet's original longshoreman claim unavailable for later claims.
Miles v. Apex Marine Corp. · Supreme Court of the United States · filed
As with Moragne, the 1972 amendments to LHWCA have rendered Gaudet inapplicable on its facts. ... Suit in Gaudet was filed before 1972.
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Limited
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The Court confined Gaudet's loss-of-society damages rule to deaths in coastal waters and refused to extend it to deaths on the high seas governed by DOHSA.
Mobil Oil Corp. v. Higginbotham · Supreme Court of the United States · filed
The Gaudet opinion was broadly written. ... Gaudet may be read, as it has been, to replace entirely the Death on the High Seas Act. ... Its holding, however, applies only to coastal waters.
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The Court confined Gaudet's loss-of-society holding to longshoremen and denied that recovery for the death of a Jones Act seaman.
Miles v. Apex Marine Corp. · Supreme Court of the United States · filed
The holding of Gaudet applies only in territorial waters, and it applies only to longshoremen. Gaudet did not consider the ... preclusive effect of the Jones Act for deaths of true seamen. We do so now.
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The Louisiana Fourth Circuit confined Gaudet to its unseaworthiness facts and affirmed denial of nonpecuniary damages for a longshoreman's death claim under maritime negligence law.
Vedros v. Public Grain Elevator of New Orleans, Inc. · Court of Appeal of Louisiana, Fourth Circuit · filed
Although the Miles court did not reverse Gaudet or specifically limit it to its facts, it seems appropriate because it creates an anomaly in the law. ... Since Gaudet, the 1972 amendments to the LHWCA and the decision of the U.S. Supreme Court in Miles evidences the trend in federal jurisprudential and statutory law to bar claims for nonpecuniary loss. For the foregoing reasons, the judgment of the trial court is affirmed.
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Declined to follow
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The Sixth Circuit expressly rejected Gaudet's reasoning as a guide to punitive damages for a seaman's death under maritime unseaworthiness law.
Miller v. American President Lines, Ltd. · Sixth Circuit · filed
Accordingly, we reject the reasoning of Gaudet, and follow instead the course set by Moragne, Higginbotham, and Miles. Looking primarily to the federal maritime wrongful death statutes for guidance, we hold that punitive damages are not available in a general maritime law unseaworthiness action for the wrongful death of a seaman.
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The Louisiana First Circuit denied nonpecuniary damages for a longshoreman's death in territorial waters and expressly refused recovery under Gaudet's rule.
Welch v. Fugro Geosciences, Inc. · Court of Appeal of Louisiana, First Circuit · filed
Therefore, we find that the trial court was correct in ruling that nonpecuni-ary damages cannot be recovered for the death of a longshoreman injured in territorial waters and, further, that to allow such recovery would ignore the tide of decisions running against Gaudet
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Criticized
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The New Jersey Supreme Court rejected Gaudet's trustee rationale for preventing duplicate recovery while deciding a state wrongful-death damages question.
Alfone v. Sarno · Supreme Court of New Jersey · filed
We do not agree with the formal notion of trusteeship suggested by Gaudet. ... The question of what duties the injured party as trustee would have towards the potential wrongful death beneficiaries demonstrates that this concept causes more problems than it resolves.
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