US Supreme Court Rules That Claim of Unseaworthiness Does Not Allow for Award of Punitive Damages
On June 24, 2019, the U.S. Supreme Court reversed the 9th Circuit's ruling of The Dutra Group v. Batterton case and ruled 6-3, holding a "plaintiff may not recover punitive damages on a claim of unseaworthiness.”
The case: Christopher Batterton was injured while working on a vessel owned and operated by The Dutra Group. A hatch cover blew open and crushed his hand because the vessel was missing a safety feature, making the vessel unseaworthy.
Batterton filed a civil action asserting one claim of negligence under the Jones Act and two claims under general maritime law: one for breach of the duty to provide a seaworthy vessel and one for breach of the duty to provide maintenance and cure.
During the suit of Dutra for punitive damages. The Ninth Circuit Court and the Fifth Circuit Court differed on “whether punitive damages can be recovered based on a claim of unseaworthiness" . The US Supreme Court held that a plaintiff may not recover punitive damages on a claim of unseaworthiness – as such claim would serve as a duplicate and a substitute for a Jones Act claim.
In his opinion, Justice Alito wrote, “Because there is no historical basis for allowing punitive damages in unseaworthiness actions, and in order to promote uniformity with the way courts have applied parallel statutory causes of action, we hold that punitive damages remain unavailable in unseaworthiness actions.”
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