International Ass'n of Machinists & Aerospace Workers Pension Plan v. Shaw

How later courts describe this case

• holding that, “[t]he Legislature is presumed to have been aware of existing legislation at the time it adopted [the statute].”
• stating that Legislature is presumed to be aware of existing legislation at time statute is enacted
• stating that the Legislature is presumed to be aware of legislation existing at the time that a statute is enacted
• noting that the Legislature is presumed to be aware of existing legislation at the time a statute is enacted
• noting that a repeal by implication requires “clear and compelling evidence of the legislative intent, and such intent must be free from reasonable doubt” and stating that “[e]very reasonable construction should be applied to avoid a finding of implied repealer”
• a repeal by implication requires clear and compelling evidence of the legislative intent free from reasonable doubt
• since the Jones Act allows for recovery of only pecuniary damages, punitive damages, as they are nonpecuniary, are not recoverable under the Jones Act
• functionality is a question of fact