In the 1995 case Yamaha Motor Corporation, U.S.A., et al. v. Lucien B. Calhoun, et al., the Supreme Court ruled in favor of Yamaha by a vote of 9-0, establishing that maritime law does not allow for damages based on loss of society in cases involving fatal accidents at sea outside territorial waters. The parents of Natalie Calhoun sued Yamaha after their daughter died while using one of its jet skis in international waters off Puerto Rico's coast. They sought compensation under general maritime law for "loss-of-society" damages (non-economic losses such as love and companionship). However, the court held that this type of damage is not recoverable under general maritime law when an accident occurs beyond U.S territorial waters.

In the dissenting opinion for Yamaha Motor Corporation, U.S.A., et al. v. Lucien B. Calhoun, et al., Justice Stevens argued that maritime law should not be used to limit damages in cases involving non-seafarers killed in territorial waters because it would undermine state wrongful death statutes and create an arbitrary distinction between deaths occurring on land versus water. He contended that the majority's decision was inconsistent with past rulings which had allowed states to supplement federal maritime law when necessary to protect their citizens' rights and interests. Furthermore, he believed there was no compelling reason why a victim's family should receive less compensation simply because the accident happened at sea rather than on land.