The case of Norfolk Shipbuilding & Drydock Corporation v. Celestine Garris, administratrix of the estate of Christopher Garris, deceased in 2000 revolved around a wrongful death claim under maritime law. The plaintiff was the mother and representative of two men who died while working on a barge owned by Norfolk Shipbuilding & Drydock Corporation (Norshipco). She claimed that Norshipco's negligence caused her sons' deaths and sought damages under Section 5(b) of the Longshore and Harbor Workers' Compensation Act (LHWCA), which allows for such claims against "vessel" owners. However, Norshipco argued it could not be sued as a vessel owner because it was also their employer - an argument based on an exception within LHWCA that protects employers from double liability. The Supreme Court ruled in favor of Mrs. Garris stating that dual capacity entities like Norshipco can indeed be held liable as vessel owners if they negligently cause their employees’ deaths or injuries despite being protected from suits as employers under LHWCA.

In the dissenting opinion for Norfolk Shipbuilding & Drydock Corporation v. Garris, Justice Thomas argued that the majority's interpretation of the Longshore and Harbor Workers' Compensation Act (LHWCA) was incorrect. He believed that it expanded liability beyond what Congress intended when they enacted this legislation. According to him, LHWCA should not provide a cause of action for negligence resulting in death because it already provides compensation for deaths occurring upon navigable waters during employment. The majority’s ruling would allow double recovery under both state wrongful death statutes and federal law which is contrary to congressional intent as expressed in Section 5(b) of LHWCA which limits employer liability to cases where injury results from their vessel's unseaworthiness or negligent operation by them or someone else on their behalf other than an employee injured while performing his duties on such vessel.