In Dutra Group v. Batterton, the United States Supreme Court held that punitive damages are not available under maritime law. Christopher Batterton sought general and punitive damages from an injury he suffered while working as a deckhand and crew member on vessels owned and operated by the Dutra Group when his hand was caught between a bulkhead and a hatch that blew open as a result of unventilated air accumulating and pressurizing within the compartment he was in. Batterton asserted a variety of claims, including negligence, unseaworthiness, maintenance and cure, and unearned wages. The Dutra Group moved to strike Batterton’s claim for punitive damages, arguing they are unavailable in unseaworthiness claims. The Supreme Court agreed, and reversed the lower court’s decision which had allowed punitive damages in unseaworthiness cases.
The Court discussed the history of maritime law, its origins in the common law, and then the Jones Act in 1920 (which codified the rights of injured mariners and created new statutory claims). Before the Jones Act, sailors could bring claims for “maintenance and cure,” which required the ship’s master to provide food, lodging, and medical services to a seaman injured while serving the ship, whether related to negligence or culpability on the part of the shipmaster or related to the seaman’s employment or not. Then claims for “unseaworthiness” grew out of causes of action unrelated to personal injury but eventually became the vehicle to remedy personal injury claims where the vessel’s owner failed to exercise due diligence. Then in the 1950s the Court decided a series of cases that transformed the old claim of “unseaworthiness” into a strict liability claim. The Jones Act and unseaworthiness claims are both designed to compensate seaman for the injuries itself and the losses resulting from the injury.
The Court viewed each maritime claim: negligence, unseaworthiness, and maintenance and cure, in its proper historical context to determine if punitive or exemplary damages were available, since each has different origins calling for application of slightly different principles and procedures.
The overwhelming historical evidence showed that punitive damages were not available for unseaworthiness claims, instead such cases discussed only compensatory damages. By the time the claim of unseaworthiness evolved to remedy personal injury, punitive damages were a well-established part of the common law, and the lack of punitive damages in traditional maritime law cases was practically dispositive here.
Since there was no historical practice of providing punitive damages in unseaworthiness cases, the Court then looked to the Jones Act. The Jones Act incorporated the rights provided to railway workers under the Federal Employers Liability Act (“FELA”) and provided injured seamen with a cause of action and right to a jury. By the time the Jones Act was passed the Court had held that the damages recoverable under FELA were limited to strictly financial losses and actual pecuniary losses. Later cases explicitly held that punitive damages were not available in FELA matters. Early cases involving the Jones Act likewise held recovery was limited to pecuniary losses and that punitive damages were not available.
The Court also refused to provide punitive damages on policy grounds, since claims for unseaworthiness in its current strict liability form was the Court’s own invention post dating the Jones Act. In its view, imposing punitive damages would exceed its role and contradict the remedies Congress has provided in similar cases, including under FELA.
This term in the Devries case, the Supreme Court looked to maritime law’s special solicitude to seaman to extend a product manufacturer’s liability to third party component products. Here, the Court determined this paternalistic approach was not a requirement that maritime law must favor sailors at all times, especially since the common law’s harsh limitations on recovery has been alleviated by the Jones Act and precedent on unseaworthiness claims. In addition, punitive damages here would place American shippers at a disadvantage because the international community restricts injured plaintiff seamen to compensatory or pecuniary damages.
The Supreme Court’s decision therefore precludes punitive damages for personal injury claims in admiralty cases or arising under maritime law. Neither the Jones Act nor personal injury claims sounding in unseaworthiness permits punitive or exemplary damages. Injured seaman are limited to pecuniary losses.