On June 24, 2019, the United States Supreme Court issued a ruling of significance to the maritime community. In a 6-3 ruling, the Supreme Court held in The Dutra Group v. Batterton that punitive damages are not available in a case alleging unseaworthiness.
The case involved the claims of Christopher Batterton, a Jones Act Seaman who was injured while working on a vessel owned and operated by The Dutra Group. Batterton alleged that a hatch cover blew open and crushed his hand due to a missing a safety feature, making the vessel unseaworthy. Batterton sued Dutra for punitive damages, among others.
The Supreme Court’s ruling resolves a significant split between precedent in the Ninth and Fifth Circuit Courts of Appeal. In 2014 , the Fifth Circuit ruled in McBride v. Estis Well Service, 768 F.3d 382, 384 (5th Cir. 2014) (en banc) that punitive damages are not recoverable in respect of vessel unseaworthiness claims. In 2018, the Ninth Circuit reached a different conclusion in Batterton v. The Dutra Group, 880 F.3d 1089 (9th Cir. 2018), finding that punitive damages are recoverable damages for unseaworthiness. In siding with the Fifth Circuit’s ruling, the Supreme Court provided needed clarity concerning the lack of availability of punitive damages for Jones Act unseaworthiness claims.