## Facts

- Christopher Batterton, a seaman, was injured while working aboard a vessel owned by The Dutra Group.
- The vessel lacked an exhaust mechanism to release pressure below a hatch.
- A hatch blew open and injured Batterton’s hand while he was on deck.
- Batterton sued in federal district court, asserting a general maritime law claim for unseaworthiness and seeking compensatory and punitive damages.
- Dutra moved to dismiss the punitive-damages demand, arguing punitive damages are not available for unseaworthiness.
- The district court denied the motion and certified the issue for interlocutory appeal.
- The Ninth Circuit affirmed, holding punitive damages were available for unseaworthiness.
- The Supreme Court granted certiorari to resolve whether punitive damages may be awarded for an unseaworthiness personal-injury claim.

## Issues

1. Whether general maritime law permits punitive damages for a seaman’s personal-injury claim based on a vessel’s unseaworthiness.
2. Whether courts may expand unseaworthiness remedies beyond limits reflected in Congress’s remedial scheme for seamen, particularly the Jones Act (incorporating FELA).

## Decision

- The Supreme Court reversed and remanded.
- The Court held that a plaintiff may not recover punitive damages on a claim of unseaworthiness.
- The Court relied on (1) the absence of a long-established historical practice of awarding punitive damages for unseaworthiness and (2) the need for remedial uniformity with Congress’s framework for seamen’s injury claims.
- The Court distinguished cases allowing punitive damages for willful failure to pay maintenance and cure because that remedy has a demonstrated historical basis and does not conflict with the Jones Act’s damages limits in the same manner.

## Legal Principles

- In formulating remedies under general maritime law, admiralty courts should look primarily to legislative enactments for policy guidance and should be cautious about creating remedies that conflict with Congress’s choices.
- Under Miles v. Apex Marine Corp., judge-made maritime remedies generally should not exceed the recovery Congress authorized for closely related seamen’s claims under the Jones Act.
- A departure from statutory guidance may be warranted only where there is a long-established historical practice supporting the specific remedy for the specific maritime claim.
- Because the Jones Act (through FELA) provides compensatory, pecuniary recovery and does not authorize punitive damages, allowing punitive damages for unseaworthiness would create remedial asymmetry for the same class of injuries and undermine uniformity.
- The historical record does not show a tradition of punitive damages for unseaworthiness claims sufficient to justify recognizing that remedy.

## Conclusion

The Court held that punitive damages are not available for a seaman’s unseaworthiness personal-injury claim under general maritime law, emphasizing both the lack of historical support for such awards in unseaworthiness actions and the need to keep judge-made maritime remedies consistent with Congress’s compensatory-only framework for seamen’s injury claims.


The Dutra Grp. v. Batterton, 139 S. Ct. 2275 (2019)