Ponder v. M/V Chilbar
May 13, 2002OUTCOME: Summary Judgement for Defendant
The seaman was injured while employed as a Jones Act seaman, and sought punitive damages from defendants for his injuries. The seaman claimed that punitive damages were available because the employee ... intentionally failed to furnish a seaworthy vessel. Defendants argued that punitive damages were not available as a matter of law because injured seamen were never entitled to punitive damages. The court agreed that punitive damages were not available. The Miles holding provided that remedies available to the seaman under the general maritime law must not exceed those remedies available to the seaman under statutory law. Therefore, because punitive damages were not available under general maritime law for unseaworthiness claims, punitive damages were also not available under the Jones Act. Furthermore, the Miles holding also provided that punitive damages could not be based upon a shipowner's intentional failure to provide a seaworthy vessel. Consequently, the seaman could not recover punitive damages for defendants' willful failure to provide a seaworthy vessel.
