Dutra Group v. Batterton

Christopher Batterton, a deckhand on a dredge owned by The Dutra Group, suffered a severe hand injury when a pressurized hatch cover blew open. He sued the vessel owner under general maritime law, asserting claims for negligence and unseaworthiness, and sought punitive damages. The district court allowed punitive damages, and the Ninth Circuit affirmed, holding that punitive damages were available for unseaworthiness claims. The U.S. Supreme Court granted certiorari to resolve a circuit split. In a 6-3 decision delivered by Justice Alito, the Court held that punitive damages are not available in unseaworthiness claims under general maritime law. It reasoned that historical maritime cases and the Jones Act do not support such recovery, and that extending punitive damages would disrupt settled maritime remedies. The decision reversed the Ninth Circuit and limited the damages recoverable by injured seamen.

The Supreme Court reversed the Ninth Circuit, holding 6-3 that punitive damages are not available in claims of unseaworthiness under general maritime law.

Whether punitive damages may be awarded to a plaintiff suing for personal injury under a general maritime law claim of unseaworthiness.

The ruling narrowed the monetary relief available to injured maritime workers, reinforcing traditional limits on shipowner liability. It emphasized judicial restraint in reshaping maritime common law without congressional action and resolved a longstanding division among federal appellate courts, thereby creating uniformity in maritime personal injury litigation.