In the case of Sea-Land Services, Inc. v. Gaudet in 1973, the U.S Supreme Court ruled that under maritime law, a widow could recover damages for loss of support and services as well as funeral expenses from her husband's employer following his death due to negligence at work. The court further held that she was also entitled to compensation for loss of society (companionship), despite this not being traditionally recognized under common law wrongful death actions. This decision expanded the scope of compensable losses in wrongful death cases arising from maritime torts beyond what had previously been established by state laws or federal statutes.

In the dissenting opinion for SEA-LAND SERVICES, INC. v. GAUDET, 1973, Justice Powell argued that the majority's decision to allow recovery for loss of society in a wrongful death action under maritime law was an unwarranted extension of existing legal principles. He pointed out that such damages had never been recognized before in federal maritime law and were not generally available at common law or under most state wrongful death statutes. Furthermore, he contended that this expansion of liability would have significant economic implications and could potentially disrupt established insurance practices within the shipping industry. He also expressed concern about potential inequities arising from allowing recovery for loss of society while denying it for other types of non-pecuniary losses like grief or emotional distress.