Dutra Group v. Batterton
139 S.Ct. 2275, 2019 U.S. LEXIS 4202, 204 L. Ed. 2d 692 (2019)
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Rule of Law:
Under general maritime law, a plaintiff may not recover punitive damages on a claim of unseaworthiness. This rule is based on the lack of historical precedent for such damages and the need for uniformity with parallel statutory remedies like the Jones Act, which limits recovery to pecuniary loss.
Facts:
- Christopher Batterton was employed as a deckhand and crew member for The Dutra Group.
- While working on a scow near Newport Beach, California, unventilated air accumulated and pressurized within a ship compartment.
- As a result of the pressure buildup, a hatch blew open.
- Batterton's hand was caught between the hatch and a bulkhead, causing him to suffer a permanent injury.
Procedural Posture:
- Christopher Batterton sued The Dutra Group in the U.S. District Court for the Central District of California, asserting claims for negligence, unseaworthiness, and maintenance and cure.
- Batterton sought punitive damages for his unseaworthiness claim.
- The Dutra Group moved to strike the claim for punitive damages.
- The District Court, as the court of first instance, denied The Dutra Group's motion.
- The District Court certified the question for an interlocutory appeal.
- On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed the District Court's decision, holding that punitive damages are available for unseaworthiness claims.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Does general maritime law permit recovery of punitive damages on a claim of unseaworthiness?
Opinions:
Majority - Justice Alito
No, general maritime law does not permit recovery of punitive damages on a claim of unseaworthiness. The Court's analysis is guided by its precedents in Miles v. Apex Marine Corp. and Atlantic Sounding Co. v. Townsend, which require examining both historical tradition and conformity with parallel statutory law. First, there is no historical basis for awarding punitive damages in unseaworthiness actions; the claim did not traditionally allow for such recovery, unlike maintenance and cure claims. Second, allowing punitive damages would create disuniformity with the primary parallel statutory remedy, the Jones Act. The Jones Act incorporates the Federal Employers' Liability Act (FELA), and courts have consistently held that both statutes limit recovery to pecuniary damages and do not authorize punitive awards. To preserve a uniform rule for personal injury actions, the common law unseaworthiness claim must align with its statutory counterpart. Policy considerations also weigh against creating this novel remedy, as it would be anomalous to impose greater liability for a strict-liability claim (unseaworthiness) than Congress has for a negligence-based claim (Jones Act).
Dissenting - Justice Ginsburg
Yes, general maritime law should permit the recovery of punitive damages on a claim of unseaworthiness. The majority incorrectly follows Miles when Atlantic Sounding is the controlling precedent. The claim of unseaworthiness, like maintenance and cure, is a traditional maritime cause of action that predates the Jones Act. Under Atlantic Sounding, the general common-law rule allowing punitive damages applies to such claims unless Congress has clearly displaced it. The Jones Act was enacted to expand, not limit, seamen's remedies and did not disturb pre-existing general maritime claims. The absence of historical cases awarding punitive damages for unseaworthiness is not dispositive; what matters is the lack of evidence that such damages were unavailable. The Court's decision creates a new, bizarre disparity where punitive damages are available for a willful failure to provide maintenance and cure but not for a willful and wanton breach of the duty to provide a seaworthy vessel.
Analysis:
This decision significantly curtails the availability of punitive damages in maritime personal injury law, limiting them primarily to maintenance and cure claims as established in Atlantic Sounding. It reinforces the principle from Miles that federal courts should prioritize uniformity between judge-made general maritime law and congressional statutes like the Jones Act, deferring to legislative policy over judicial creation of remedies. The ruling signals a judicial reluctance to expand non-pecuniary damages under general maritime law, especially where statutory and common law claims for the same injury overlap. This approach will likely limit the development of other judicially-created remedies in maritime law, pushing such matters to the legislative branch.
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