Prior to DOHSA's enactment, advocates for the bill were concerned that no remedies were available for an individual who died on the high seas, which are outside of the reach of state and federal jurisdiction.52 CONG. REC. 284-85 (daily ed. Dec. 16, 1914) The Bill received support from the judicial branch as well, with some individuals noting a need for a uniform law to apply to these types of maritime disputes. Several versions of DOHSA were introduced to Congress on three occasions between 1900 and 1915, but the Act failed to pass each time.Madeline Burke, The 1920 Death on the High Seas Act: An Outdated and Ambiguous Admiralty Law Shielding Cruise Line Companies from Civil Liabilities, 49 J. MAR. L. & COM. 1 (2018) – via Westaw  After the Titanic sank in 1912, awareness of maritime deaths increased, and the Act finally passed in 1920. DOHSA is viewed as an exercise of Congressional implied powers to "revise and supplement the maritime law within the limits of the Constitution."Romero v. Int'l Terminal Operating Co., 358 U.S. 354, 361 (1959)
