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American seamen have three avenues of recovery against a shipowner in respect of injuries sustained on board a ship: maintenance and cure; the Jones Act; a claim of unseaworthiness.

Punitive damages are available for the first of these, but not the second. The position as regards unseaworthiness was, until recently, unclear with a Circuit split on the issue. This has now been resolved by the Supreme Court’s decision in Dutra Group v Batterton ,588- U.S.. ____ BuckleDown DCWMP009WS Dog Collar Seatbelt Buckle, Mopar Logo Repeat Black White, 1.5 by 1318 6 L60cm60cmDSADDSD Pet House Kennel Cat Litter Round Small And Medium Kennel Mat Four Seasons Universal Comfortable Pet Supplies (color 7 , Size L60cm60cm)(2019) , to the effect that punitive damages are not recoverable. The  overwhelming historical evidence was against such damages being available in an action for unseaworthiness. A  novel remedy could not be sanctioned unless it is re­quired to maintain uniformity with Congress’s clearly expressed poli­cies, B LargePet house Dog Bed,Comfortable Pet Nest Indoor Shortlived Fluff Cold Predection Moisture Proof 4 Sizes (color D, Size Xl)B Blesiya Parred Travel Carried Backpack Space Capsule Pet Bird Outdoor Perch with Feeding Cup and Reusable Bird Diaper Parakeet Cockatiels Chest Cover (Pink)particularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Coastal bluee 48 Kurgo Springback(TM) Dog Leash, Red Black, 48 BiOrb 46096.0 Sea Fan Medium Pink Aquariums.

To allow punitive damages on unseaworthiness claims would create bizarre disparities in the law. First, a mariner could make a claim for punitive damages if he was injured onboard a ship, but his estate would lose the right to seek punitivedamages in a wrongful death action if he died from his injuries. AYLS Cat Scratch Cat House Recyclable Cardboard DIY Assembly Predect Your Furniture Scratchpad Mat Cat Indoor Apartment Activity CenterAQUARISTIKWELT24 7264 Aquarium Root 78 x 25 x 66 cm XXL Wood DecorationSecond, because unseaworthi­ness claims run against the owner of the vessel, the owner could be liable for punitive damages while the ship’s master or operator—who could be more culpable—would not be liable for such damages under the Jones Act. Aquael Uni Filter 1000 UV Internal FilterAntos Toothbrush Vegetable Dog Treats, Large, 1 x 50Third, allowing punitive damages would place Amer­ican shippers at a significant competitive disadvantage and discour­age foreign-owned vessels from employing American seamen

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It’s not often that we can say “You read it first on the IISTL blog.” But it seems we may be able to, following the decision of the Court of Appeal (Males, Rose and Haddon-Cave L.JJ.) in Alapet Multicolor Optional ABS, PC Pet Space Bag, Internal AntiBreakOff Pet Portable Breathable Backpack, Comfortable Handle Design, Reinforced Adjustable Strap, Fashion Style (color Pink).

The facts briefly recap thus. A charterer signed a CoA promising to come up with vast cargoes of Brazilian iron ore that would have netted the shipowner profits of something like $20 million. It didn’t, and in hindsight it was abundantly clear that it it never could have. Black SmallPet Backpack,Pet Carrying Bag,Can Be Folded Portable Breathable Dog Cat Carrying Bag,Pet Nylon Carrier PouchBulldog Bowl Pet Ceramic Pot Suitable for Small and Medium Dogs Bowl Catch and Perfect Dining Table (Black)The contract was subject to a force majeure clause including floods preventing performance. Floods duly materialised; but (as was held both at first instance and on appeal) the charterer couldn’t invoke the clause, since if it had never had any cargoes in the first place the floods hadn’t prevented it doing anything. Nevertheless Teare J Beeztees Bird Cage Iza 2 Pagode, 45 x 28 x 59, 5 cm, Silver 6Pcs Home Pet Dog Grooming Scissors Set, Professional Dogs Cats Trimming Scissors Cutting Curved Thinning Shears with Combs Hemostat Kits Pets Hair Cutting Tools 7.0 Bright White 2 x 115cmInterpet LED Lighting System, Triple Bright White, 75 cmthat even though there was breach the damages were not $20 million, but zilch (or rather nominal). His argument was that, hindsight having shown that the shipowner wouldn’t have had a right to performance even if the cargoes had been there, the value of the lost rights was zero.

We raised an eyebrow here at the idea that a defendant who hadn’t, and never could have, performed should be able to cut damages from $20 million to zero by pointing to a force majeure clause that might have protected him but in fact didn’t. bluee Bits Turkey 4oz by SummitBuddha Statue Indoor Fountain, Feng Shui Ornaments, Resin Waterfall for Home Decor with LED color Lights, Crystal Ball, Water pumpThe Court of Appeal has now made it clear that it thinks the same way, and substituted an award of $20 million. If (it was said) a claimant showed that a defendant had failed to perform and the defendant could not invoke any exculpatory provision, there was no reason why damages should not be substantial. The reasons behind the non-performance were irrelevant,Binglinghua 22 Diameter Dog Agility Jumping Training Hoop Outdoor Pet Agility Exercise Sports Obedience Show Dogs Activity Hoop Jump GameA Small Pet Casual Summer Canvas Cap Dog Baseball Visor Hat Puppy Outdoor Duck Tongue Sunshade Hat,H as was the fact that had the defendant been able to perform in the first place he would have had an excuse.

In our view, despite the beguiling advocacy of the Institute’s own Simon Rainey QC, this is sensible and logical. Males LJ hit the nail on the head at [89] when he pithily pointed out that the breach was not inability or unwillingness to supply cargoes, but the simple fact that the cargoes, for whatever reason, were not there. Put that way, everything neatly falls into place. If you don’t perform your contract and can’t point to any excuse, you are liable for substantial damages. End of story.

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Last year we reported on two judicial review challenges to government policy on climate change, one in the Netherlands, the other in the UK.

The Netherlands challenge brought by Urgenda resulted in an order that that the Netherlands State be ordered to achieve a reduction so that the cumulative volume of Netherlands greenhouse gas emissions would be reduced at least by 25%, by the end of 2020, relative to 1990 levels. The Netherlands State appealed against the order and the Dutch Supreme Court heard the case on 24 May 2019 and a judgment is expected over the summer.

The UK challenge was brought by Plan B and sought judicial review of the UK government’s decision not to amend the 2050 target in the Climate Change Act 2008 in the light of article 2(1) (a) the 2015 Paris Agreement on Climate Change, which the UK has ratified, AQUARISTIKWELT24 Bonsai Tree M Original Photo No. 10152 Root Wood Aquarium Decoration Aquascaping Bonsai Tree Decoration Landscape Mossthe parties commit to:BuckleDown DLW31442N Narrow 0.5 New York's Five Burroughs Bold Black White Dog Leash, 4'colorado Saddlery The Classic Curb Bit, Stainless Steel “Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognising that this would significantly reduce the risks and impacts of climate change.” The challenge failed and leave to appeal was rejected earlier this year.Bob & Lush Delicious 60% Duck Kibble. Super Tasty Kibble with 100% Fresh Meat for Discerning Puppies and Juniors (Delicious Duck with without Gravy, 15kg)Brown L=25.6\GTTBS Cat Bed Breathable Comfort Bite Removable Washable Waterproof MoistureProof Dog Bed Cationic Oxford Cloth Winter HighGrade Warm Pet Bed,Brown,L=25.6 21.7 7

Since then the UK Committee on Climate Change, in line with the findings of the IPCC in October 2018, has recommended a new emissions target for the UK of net-zero greenhouse gases by 2050. The previous target was to ensure that the net UK carbon account for the year 2050 (“the 2050 target”) is at least 80% lower than the 1990 baseline. This week a statutory instrument, the Climate Change Act 2008 (2050 Target Amendment) Order 2019, Casual Canine ZA1063 12 19 LED Collar 1216In blueBlack+white MediumRising S Pet Travel Bag,pet Backpack For Dogs Pet Backpack Carrier For Small Dogs Breathable Folding Waterproof Handbag Shoulder Travel Pet Backpack Carrier,Black+whiteMwas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.Blazin' Safety LED Dog Collar USB Rechargeable with Water Resistant Flashing Light Medium ChristmasArmyGreen XLQinniao Widebred Dog Chest Strap Large Dog VestStyle golden Retriever Dog Strap Pet Dog Vest Swimwear Life Jacket Gift Leash Quality Life Jacket (color ArmyGreen, Size XL).

This is a ‘net’ figure, which allows for the ability to use international carbon credits to offset emissions within an appropriate monitoring, reporting and verification framework. In addition, under s.30(1) of the Act emissions from international aviation and shipping do not count as emissions from sources in the UK. Bomber Tattini Unisex Softshell tecnoleggero Clothing Riding TattiniThe Government have said that they will review the ‘net zero’ target within 5 years to check that other countries are following suit, and, if not, reserve the right to revert to the original 80% target.

To stabilise at 1.5 degrees over pre industrial levels by 2100 the IPCC has stated that levels of CO2 in the atmosphere should not exceed 430 parts per million, and for stabilising at 2 degrees the levels should not exceed 450 per million. Clean Go Pet ZW945 11 RakeStyle Sanitary Dog Poop Scoop Set, with PanChromePlated SteelBrown+white Dog Handbag Go Out Carrying Case Car Kennel Pet Travel Bag Portable Pet Bed Foldable and Hand Washable 42×48×41cm (color Brown+White)A ZXH77f Dog Cat Slave Favorite Leopard Pet Dogs Cats Bed Nest Litter Toys Pad Mobile Activity Playing Blanket House Pets Furniture (color A)Last month a reading at a weather station in Hawaii recorded 415 parts per million of CO2 in the atmosphere. The current annual rate of increase is in the order of 3 parts per million.