Dutra Group v. Batterton

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Admiralty
  • Date Filed: June 24, 2019
  • Case #: 18-266
  • Judge(s)/Court Below: ALITO, J., delivered the opinion of the Court, in which R OBERTS, C. J., and THOMAS, K AGAN, G ORSUCH, and K AVANAUGH, JJ., joined. G INSBURG, J., filed a dissenting opinion, in which B REYER and SOTOMAYOR, JJ., joined.
  • Full Text Opinion

Punitive damages are unavailable for mariner plaintiffs in claims of unseaworthiness.

Respondent is a mariner that was injured while working on Petitioner’s vessel and sought general and punitive damages in federal court.  Petitioner moved to dismiss the punitive damages claim, arguing punitive damages are not available for unseaworthiness actions.  The district court denied the motion but certified an interlocutory appeal on the question. The Ninth Circuit Court of Appeals affirmed, holding punitive damages are available for claims of unseaworthiness, reaffirming a circuit court split on the issue. The Supreme Court reversed, following precedent in Miles v. Apex Marine Corp., 498 U. S. 19 (1990), and Atlantic Sounding Co. v. Townsend, 557 U. S. 404 (2009).  Miles established the primary focus for the Court is to consider “legislative enactments for policy guidance,” but also stated that the Court may supplement statutory remedies to ensure the policies served by the statutes are upheld. In Atlantic Sounding, the Court allowed a punitive damage award noting a historical basis for “certain maritime torts, including maintenance and cure.” In the instant case, finding no historical basis or precedent to allow punitive damages for unseaworthiness and to further uniform application in decisions, the Court held that punitive damages “remain unavailable in unseaworthiness actions.”  REVERSED and REMANDED.

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