Supreme Court denies right to punitive damages in unseaworthiness claim News
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Supreme Court denies right to punitive damages in unseaworthiness claim

The US Supreme Court on Monday denied a seaman the right to punitive damages for an unseaworthiness claim.

Christopher Batterton was a deckhand for The Dutra Group on various vessels. Batterton’s hand was permanently damaged when a hatch blew open and crushed it due to a buildup of pressurized air below deck. Batterton sued The Dutra Group under a number of claims including negligence and unseaworthiness. Batterton sought to recover both general and punitive damages. The Dutra Group attempted to have the claim for punitive damages dismissed arguing that punitive damages are not traditionally available in unseaworthiness claims. The district court denied the motion, and the appeals court affirmed leading to a split in the circuits. The Supreme Court took on the case hoping to resolve it.

In a 6-3 opinion written by Justice Samuel Alito, the majority rejected the availability of punitive damages in unseaworthiness claims. The majority found that punitive damages are not a traditionally available remedy in unseaworthiness actions. The majority, likewise, found no right to punitive damages for unseaworthiness actions codified in the Jones Act, which granted seamen explicit rights and remedies similar to those previously available to railroad workers. The majority also opined that granting punitive damages available for injury but denying them in death would create an odd circumstance of the law. Finding no possibility of punitive damages available, the majority declined to create one here.

Justice Ruth Bader Ginsburg, writing for the dissent, argued that punitive damages have been allowed for unseaworthiness at common law and should be allowed here. Ginsburg challenged the majority’s view that the punitive damages would be double compensating the plaintiff for a singular injury and instead asserts that punitive damages serve a completely different purpose. Ginsburg defined punitive damages as serving to punish an offender to deter “lawless misconduct”.

With the court’s opinion the case will now be remanded to the Ninth Circuit where Batterton will only have pecuniary damages available for his claims.

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