Yamaha Motor Corp., U.S.A. v. Calhoun

In 1989, 12-year-old Natalie Calhoun was on vacation at a resort in Puerto Rico when she was killed in a jet ski accident. Natalie’s parents (the Calhouns) (plaintiffs) filed suit against the jet ski manufacturer, Yamaha Motor Corp., USA (Yamaha) (defendant). The Calhouns alleged that the jet ski was negligently designed. The Calhouns sought to recover damages under state survival and wrongful-death statutes. Yamaha argued that the Calhouns could not recover based on state statutes because Natalie had died on navigable waters and therefore maritime law controlled. The district court ruled that maritime law displaced state law. Accordingly, under maritime law, the Calhouns could recover damages for Natalie’s funeral expenses and damages for the loss of society and loss of support and services. Yamaha and the Calhouns both requested an immediate interlocutory appeal. The district court granted the request and prepared a certified order to the court of appeals. The certified order asked the court of appeals whether, under maritime law, plaintiffs could recover damages for the loss of the society, damages for loss of support and services, and punitive damages. The district court did not present the appellate court with the question of whether maritime law controlled. However, the court of appeals chose to consider whether maritime law controlled. The court of appeals held that maritime law did not control and that the Calhouns could recover all remedies provided for by state law. The matter was appealed. The United States Supreme Court granted certiorari.