Sea-Land Services, Inc. v. Gaudet’s Empirical Analysis
1974
Citation profile
461 federal appellate · 142 district · 243 state decisions
How this case has been cited
Cited by 1,559 later decisions (21 by the Supreme Court) — most recently April 2025 · most notably Taylor v. Sturgell (2008), Miles v. Apex Marine Corp. (1990)
461 federal appellate · 142 district · 243 state decisions — followed in 30 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedGaudet v. Sea-Land Services, Inc. (from Fifth Circuit Court of Appeals)
Relationships
Applies 45 U.S.C. § 51 (Federal Employers' Liability Act) · 45 U.S.C. § 59 (Federal Employers' Liability Act)
Relies on Commissioner v. Sunnen · Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation · Cromwell v. County of Sac · Moragne v. States Marine Lines, Inc. · The Harrisburg
Cited together with Moragne v. States Marine Lines, Inc. · Mobil Oil Corporation v. Higginbotham K · Miles v. Apex Marine Corp. · The Harrisburg · American Export Lines, Inc. v. Alvez
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 1,559 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“loss of support, services, and society, as well as funeral expenses.”
51 later decisions quote this exact passage · from the majority“not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose.”
21 later decisions quote this exact passage · from the majority“Loss of society must not be confused with mental anguish or grief, which is not compensable under the maritime wrongful-death remedy. The former entails the loss of positive benefits, while the latter represents an emotional response to the wrongful death. The difference between the two is well expressed as follows: ‘When we speak of recovery for the beneficiaries’ mental anguish, we are primarily concerned, not with the benefits they have lost, but with the issue of compensating them for their harrowing experience resulting from the death of a loved one. This requires a somewhat negative approach. The fundamental question in this area of damages is what deleterious effect has the death, as such, had upon the claimants? In other areas of damage, we focus on more positive aspects of the injury such as what would the decedent, had he lived, have contributed in terms of support, assistance, training, comfort, consortium, etc. ‘The great majority of jurisdictions, including several which do allow damages for other types of nonpecuniary loss, hold that the grief, bereavement, anxiety, distress, or mental pain and suffering of the beneficiaries may not be regarded as elements of damage in a wrongful death action,’ [S. Speiser, Recover for Wrongful Death § 3.45, p. 223 (emphasis in original) (footnotes omitted).]”
11 later decisions quote this exact passage · from the dissent
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.