On Monday, the U.S. Supreme Court ruled in Dutra Group v. Batterton that a seaman may not recover punitive damages on an unseaworthiness claim, overruling the Ninth Circuit and resolving a split between the Fifth and Ninth Circuits.
Plaintiff Christopher Batterton was working as a deckhand on a vessel owned by defendant Dutra Group when a hatch blew open injuring his hand. Batterton sued Dutra asserting an unseaworthiness claim and seeking general and punitive damages. Dutra moved to dismiss the claim for punitive damages arguing that they are not available under unseaworthiness claims.
The district court denied Dura’s motion and the Ninth Circuit affirmed. That decision created a split between circuits because the Fifth Circuit in 2014 held that punitive damages are not available in unseaworthiness cases.
In a 6-3 decision, the Supreme Court reversed the Ninth Circuity ruling. Writing for the majority, Justice Alito explained that “the overwhelming historical evidence suggests that punitive damages are not available” on an unseaworthiness claim. The majority distinguished the Supreme Court’s prior ruling in Atlantic Sounding Co. v. Townsend, which established that punitive damages are recoverable under “maintenance and cure” claims. Justice Alito pointed out that the Court in Townsend relied on an established historical record of punitive damages in maintenance and cure cases, and he noted that there is no similar historical record in unseaworthiness cases.
The majority opinion emphasized that remedies available for a personal injury claim under general maritime law should be consistent with those available under the Jones Act, which regulates maritime commerce. Since federal courts have uniformly held that punitive damages are not available in a Jones Act negligence action, the majority concluded that it could not allow more expansive remedies for Batterton’s common law unseaworthiness claim.
Finally, Justice Alito noted that adopting the Ninth Circuit view would put the American shipping industry at a competitive disadvantage because other nations generally do not impose punitive damages for unseaworthiness claims.
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