Dutra Group v. Batterton

Whether punitive damages may be awarded to a Jones Act seaman in a personal injury suit alleging a breach of the general maritime duty to provide a sea-worthy vessel.

Respondent, Batterton, sued Petitioner, Dutra Group, asserting several claims stemming from an injury allegedly suffered while employed by Petitioner as a Jones Act seaman. Under the claim brought for “breach of duty to provide a seaworthy vessel,” Respondent sought punitive damages. Petitioner moved to dismiss this claim, arguing that punitive damages are unavailable in unseaworthiness actions. The district court denied the motion and the Ninth Circuit Court of Appeals affirmed in an interlocutory appeal. In Petitioner’s brief to the Supreme Court, Petitioner argues that the decision below conflicts with the Court’s decision in Miles v. Apex Marine Corp., 498 U.S. 19 (1990), the Fifth Circuit Court of Appeals, and several other federal and state appellate court decisions. In Miles, the Supreme Court held that punitive damages in unseaworthiness actions are not authorized by Congress under the Jones Act, 46 U.S.C. § 30104. Petitioner argues that the Ninth Circuit’s decision based on Atlantic Sounding Co. v. Townsend, 557 U.S. 404 (2009), is erroneous because Townsend authorizes punitive damages in maintenance and cure claims and does not govern claims of unseaworthiness. Petitioner further argues that uniformity under maritime law for recovery of injuries is of the utmost importance to the Court and Congress. Petitioner warns that a further split on this issue will result in detrimental consequences for the maritime industry and the United States.