In a much-anticipated decision, the U.S. Supreme Court held this morning that punitive damages are not available in unseaworthiness claims. Justice Alito authored the 6-3 opinion in Dutra Group v. Batterton. The case asks whether a seaman may recover punitive damages on a claim that he was injured as a result of the unseaworthy condition of the vessel.
Dutra group v. Batterton Background
The plaintiff was working on a vessel owned by the Dutra Group when a hatch blew open and injured his hand. He sued Dutra, asserting a variety of claims, including unseaworthiness, and seeking general and punitive damages. Dutra moved to dismiss the claim for punitive damages, arguing that they are not available on claims for unseaworthiness. The California District Court denied Dutra’s motion, and the Ninth Circuit affirmed. Dutra then appealed to the U.S. Supreme Court, which granted cert to resolve a significant split between the Circuits.
U.S. Supreme Court’s Decision
The Court thoroughly examined the history of unseaworthiness claims, which dates back to the early 20th century in the present form of allowing personal injury claimants to recover due to the unseaworthy condition of the vessel. This is contrasted by the ancient history of an employer’s maintenance and cure obligations, for which punitive damages are available to a plaintiff.
The Court relied primarily on its 1990 decision in Miles v. Apex Marine Corp. for the rule that courts should look to legislative enactments for policy guidance, while recognizing that such statutory remedies may be supplemented to “achieve the uniform vindication” of the policies served by the statutes. In short, the Court was not persuaded by the case law presented by the plaintiff, finding insufficient evidence that punitive damages were historically available to a seaman in an unseaworthiness claim: “the lack of punitive damages in traditional maritime law cases is practically dispositive.”
The Court then looked to the Jones Act to determine whether punitive damages should be available to maintain uniformity with congressional policy making. The Federal Courts of Appeals have uniformly held that punitive damages are not available under the Jones Act. The Court concluded that “adopting the rule urged by Batterton would be contrary to Miles’s command that federal courts should seek to promote a “uniform rule applicable to all actions” for the same injury, whether under the Jones Act or the general maritime law.”
impact of the supreme court’s Decision
Perhaps the most notable takeaway from the Batterton decision is the Court’s rejection of the plaintiff’s policy argument that the maritime doctrine encourages special solicitude for the welfare of seamen. The Court essentially found that this paternalistic doctrine was obsolete and no longer applicable following enactment of the Jones Act and other 20th century remedies: “while sailors today face hardships not encountered by those who work on land, neither are they as isolated nor as dependent on the master as their predecessors from the age of sail. In light of these changes and of the roles now played by the Judiciary and the political branches in protecting sailors, the special solicitude to sailors has only a small role to play in contemporary maritime law.”
This reversal is a noteworthy development for ship owners and maritime employers.
Previous Articles on Dutra v. Batterton
Mouledoux, Bland, Legrand & Brackett’s maritime attorneys have been following Dutra Group V. Batterton as the case moved through the courts. Following are three articles they have written that provide additional background.