Landmark Ruling in US on Punitive Damages for Injuries in Unseaworthiness Claim
Dutra Group v. Batterton: The United States Supreme Court has issued a decision on whether punitive damages may be awarded to a Jones Act seaman alleging unseaworthiness of a vessel.
The incident involved a seaman working on board the defendant’s vessel when a hatch blew open and injured his hand. He then sought punitive damages for an alleged unseaworthy condition of the vessel that allegedly caused his injury.
The Supreme Court held that an injured seaman may not recover punitive damages for injuries caused by the unseaworthy condition of a vessel. This landmark decision resolved the conflicting law that existed on this issue between the Ninth Circuit and the Fifth Circuit.
The decision of the US Supreme Court will provide clarity on a long-standing inconsistency in the way that lower courts have ruled on the availability of punitive damages to Jones Act seamen.
Whilst the US Supreme Court’s decision in Miles v. Apex Marine Corp. (1990), previously made it clear that a Jones Act seaman cannot recover punitive damages in connection with a Jones Act negligence claim, some courts, however, have effectively bypassed Miles by holding that punitive damages were nevertheless available to seamen in connection with an unseaworthiness claim.
The Batterton decision “eliminates that loophole and provides consistency.” Therefore, it is now clear that a Jones Act seaman cannot recover punitive damages in connection with either negligence or an unseaworthiness claim.
The decision does not displace its earlier ruling in Atlantic Sounding v Townsend, holding that employers may be liable for punitive damages for the “wilful and wanton disregard” of maintenance and cure obligations.