Supreme Court Decides Dutra Group v. Batterton

On June 24, 2019, the United States Supreme Court decided Dutra Group v. Batterton, No. 18-266, holding that a plaintiff may not recover punitive damages on a claim of unseaworthiness.

Christopher Batterton worked as a deckhand and crew member on vessels owned and operated by the Dutra Group. While working, Batterton injured his hand. Batterton sued Dutra Group and asserted a variety of claims, including unseaworthiness, seeking to recover general and punitive damages. Dutra Group moved to strike Batterton’s claim for punitive damages, arguing that they are not available on claims for unseaworthiness. The District Court denied Dutra Group’s motion, and the Ninth Circuit affirmed.

The Supreme Court reversed. Initially, the Court noted that maritime law is no longer solely the province of the Federal Judiciary, and that Congress and the States have now legislated extensively in these areas. Thus, when exercising its inherent common-law authority, the Court looks primarily to these legislative enactments for policy guidance. The Court departs from the policies found in the statutory scheme in only discrete instances based on long-established history, and only cautiously in light of Congress’ persistent pursuit of uniformity in the exercise of admiralty jurisdiction.

The Court discussed that it had confronted similar questions in the past several decades, and its holdings in both cases were based on the particular claims involved. In one, which concerned a wrongful death claim under the general maritime law, recovery was limited to pecuniary damages, which did not include loss of society. And in the second, on a claim of maintenance and cure, after examining centuries of relevant case law, the Court held that punitive damages were not categorically barred. Thus, in order to determine the remedies for unseaworthiness, the Court considered both the heritage of the cause of action in the common law and its place in the modern statutory framework.

Upon review, the Court found no historical basis for allowing punitive damages in unseaworthiness actions and, in order to promote uniformity with the way courts have applied parallel statutory causes of action, the Court held that punitive damages remain unavailable in unseaworthiness actions. The Court further reasoned that punitive damages for unseaworthiness were not warranted on policy grounds or as a regulatory measure. To do so would introduce novel remedies contradictory to those provided by Congress in similar areas, creating bizarre disparities in the law. Indeed, to permit punitive damages for unseaworthiness would be contrary to the command that federal courts should seek to promote a uniform rule applicable to all actions for the same injury, whether under clearly expressed congressional policy or the general maritime law. Accordingly, a plaintiff may not recover punitive damages on a claim of unseaworthiness.

Justice Alito delivered the opinion of the Court in which Chief Justice Roberts and Justices Thomas, Kagan, Gorsuch, and Kavanaugh joined. Justice Ginsburg filed a dissenting opinion in which Justices Breyer and Sotomayor joined.