American Export Lines, Inc. v. Alvez
In American Export Lines, Inc. v. Alvez, 446 U.S. 274, 100 S.Ct. 1673, 64 L.Ed.2d 284 (1980), the Supreme Court held that general maritime law allowed the wife of a harbor worker to bring an action for damages for loss of society due to a maritime tort suffered by her husband.
Although Death on the High Seas Act ("DOHSA") and the Jones Act did not themselves provide such non-pecuniary damages, the Court allowed them, reasoning a la Gaudet that DOHSA was the exclusive remedy only for "fatal injuries incurred on the 'high seas,' " American Export Lines, 446 U.S. at 282, 100 S.Ct. at 1678, and that "the Jones Act does not exhaustively or exclusively regulate longshoremen's remedies," id. at 282-83, 100 S.Ct. at 1678