ABSTRACT
Maritime law is one of the most complex areas of American law. No aspect is more tangled than the remedies for maritime wrongful deaths of "non-seafarers," that is, those who are not seamen or longshore workers. Historically, the basic building blocks for any successful tort action have remained constant, wrongful death and maritime cases being no exception. The court must have "jurisdiction over the subject matter." In 1989, a twelve-year-old Pennsylvania girl, Natalie Calhoun, was killed in a Jet Ski accident in the territorial waters of Puerto Rico while vacationing at a resort there. Natalie's parents sued the Jet Ski manufacturer for product liability in federal court in Pennsylvania, which had long-arm jurisdiction over the defendant. The Third US Circuit Court of Appeals decided that the basic, underlying liability issues would be governed by substantive general maritime law to maintain uniform national standards of maritime behavior.
