Dutra Groupv.Batterton
Christopher Batterton was injured when a hatch on a vessel owned by the Dutra Group blew open. He sued under maritime law, including an unseaworthiness claim, and sought punitive as well as compensatory damages. The district court denied Dutra’s motion to dismiss the punitive-damages request, and the Ninth Circuit affirmed. The Supreme Court reversed. Looking to maritime history, the Jones Act, and the need for uniform remedies, the Court held that punitive damages are unavailable for an unseaworthiness claim. The Court distinguished its earlier decision allowing punitive damages for the traditional maritime claim of maintenance and cure, reasoning that unseaworthiness lacks the historical and statutory foundation needed for that remedy. It also rejected policy arguments that would create different remedies for closely related maritime injuries. The judgment was reversed and remanded. Justice Ginsburg, joined by Justices Breyer and Sotomayor, dissented, concluding that maritime law historically permitted punitive damages for serious misconduct.
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