Following the lead of several other federal circuits, the U.S. Court of Appeals for the Ninth Circuit reversed the dismissal of a wrongful death claim under the admiralty jurisdiction after holding that the claim can only accrue on or after the death of the seaman, not before.

Sherri Deem appealed to the Ninth Circuit after the U.S. District Court for the Western District of Washington said her wrongful death claim for her husband’s death had expired under a three-year statute of limitations.