Wrongful death statute
"[I]n The Harrisburg, this Court held that maritime law does not afford a cause of action for wrongful death."
"This Court overruled The Harrisburg. After questioning whether The Harrisburg was a proper statement of the law even in 1886, the Court set aside that issue because a 'development of major significance ha[d] intervened.' Specifically, the state legislatures and Congress had rejected wholesale the rule against wrongful death [in maritime law]. Every State in the Union had enacted a wrongful death statute. In 1920, Congress enacted two pieces of legislation creating a wrongful death action for most maritime deaths."