Law School Case Brief
Dutra Grp. v. Batterton - No. 18-266, 2019 U.S. LEXIS 4202 (June 24, 2019)
Punitive damages are not a traditional remedy for unseaworthiness. The Miles rule--promoting uniformity in maritime law and deference to the policies expressed in the statutes governing maritime law--prevented the recognition of a new entitlement to punitive damages where none previously existed. A plaintiff may not recover punitive damages on a claim of unseaworthiness.
Respondent deckhand Christopher Batterton was working on a vessel owned by petitioner Dutra Group when a hatch blew open and injured his hand. Batterton sued Dutra, 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. He sought punitive damages, alleging that Dutra’s breach was wanton and willful. The District Court denied Dutra’s motion to strike or dismiss Batterton’s punitive damages. The United States Court of Appeals for the Ninth Circuit affirmed.
Can injured plaintiff deckhand recover punitive damages from a vessel owner on a claim of unseaworthiness?
The Supreme Court of the United States reversed the judgment. Batterton argues that punitive damages are justified on policy grounds or as a regulatory measure. But unseaworthiness in its current strict-liability form is this Court’s own invention and came after passage of the Jones Act, and a claim of unseaworthiness serves as a duplicate and substitute for a Jones Act claim. It would, therefore, exceed the Court’s objectives of pursuing policies found in congressional enactments and promoting uniformity between maritime statutory law and maritime common law to introduce novel remedies contradictory to those provided by Congress in similar areas. Allowing punitive damages on unseaworthiness claims would also create bizarre disparities in the law. First, due to Miles’s holding, which limited recovery to compensatory damages in wrongful-death actions, a mariner could make a claim for punitive damages if he was injured onboard a ship, but his estate would lose the right to seek punitive damages if he died from his injuries. Second, because unseaworthiness claims run against the owner of the vessel, the owner could be liable for punitive damages while the ship’s master or operator—who could be more culpable—would not be liable for such damages under the Jones Act. Finally, allowing punitive damages would place American shippers at a significant competitive disadvantage and discourage foreign-owned vessels from employing American seamen. The maritime doctrine mentioned by Batterton, which encourages special solicitude for the welfare of seamen, has its roots in the paternalistic approach taken toward mariners by 19th century courts and has never been a commandment that maritime law must favor seamen whenever possible.
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