Today, the U.S. Supreme Court resolved a Circuit Split, holding that punitive damages are not recoverable to a seaman under an unseaworthiness claim. The Court, in a 6-3 ruling, sided with the U.S. Fifth Circuit’s analysis under McBride and reversed the U.S. Ninth Circuit’s decision in Dutra v. Batterton. The Court followed Townsend, in which the Court previously allowed punitive damages for failure to pay maintenance and cure under General Maritime Law, but recognized the distinction between such a claim and the historical prohibition of punitive damages for unseaworthiness claims. The Court reasoned that unseaworthiness in its current form was purely the Court’s own invention, which came after the passage of the Jones Act. In what is sure to be good news for vessel owners and Jones Act employers, the Supreme Court re-enforced the governance of the Miles uniformity principle between maritime statutory law and maritime common law.
The Court’s full decision can be read here.