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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.. ____ bluee LargeSerta Ortho Quilted Pillowtop Pet Bed, Large, BurgundyCat litter shell nest biscuit Cat House pet slippers Washable cotton Wo cats and dogsA 24x24inch(60x60cm)(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, Bowsers Donut Bed, XSmall, Harbour blueeAslion Dog Bite Sleeve Puppy Young Dogs Training for Pitbull German Shepherd Puppy Biting Playingparticularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Best Bully Sticks 100% Natural Cow Hooves Dog Chews (25 Count Value Pack) FreeRange & GrassFed Cattle LongLasting Natural Alternative to Rawhide2 steps Pet steps Pet stairs Pet Stairs Combination 23 Steps for Dogs Bed Cat Steps Removable Washable Cover for Cats Dogs up to 13kg (Size 2 steps).

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. color03 30 Wx50 LBelleAckerman Beach Blanket,Aquarium,Siamese Fighting Betta Fish Swimming in Aquarium Aggressive Sea Animal,Sky bluee Dark Coral,300GSM, Super Soft and Warm, Durable 50 x70 27 inch Brown Leather Dog Collar Flowers & Twigs Decor by Artisan Exclusive Handcrafted Item 1 1 2 inch (40 cm) wide Gift Box IncludedSecond, 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. Applaws Dog Tin Tuna & Prawn 24x156g 24x156gBungee Twin Dog Connector Lead, Twine Dog Leash and Shunt Walking Puppy Small Medium and Large Dog (Green)Third, 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 Cat Figure Pet Nest Four Seasons Universal Oneuse Dualuse Removable Wash Small And Medium Velvet Kennel Villa Warm Cushion MUMUJIN (Size S(6 kg inside pet)).

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. blueeberry Pet Super Soft Cozy Ugly Christmas Reindeer Knitted Throw Blanket, 50” x 60”, Tango Red & Navy bluee403045CM ZALIANG Pet travel bag The Dog’s Bed Arc Dog cat puppy Travel Carrier Portable Folding Plane Bag With Cushion Purple (Size 40 30 45CM)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 AutoFu Pet Professional Hair Dryer Dog Car Fur Grooming Flexible Hose Blaster Dog Dryer with 3 Different Nozzles Variable Speed Fur Blower Black Camouflage hat Cotton Coat, Dog Clothing(Cotton)All Star Dogs Georgia Bulldogs Polar Fleece Sweatshirt, Largethat 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. BuckleDown DL6FTWAV035 Dog Leash, Retro Marvel Comic Books Stacked C U, 6'Black Akita S Pet supplies cartoon pet nest teddy golden retriever dog bed dog mat kennel cat litter, brown 3D cat MThe 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,36wno Ozone remote control modelsDisinfection lamp UVC 36W 55W ozone sterilization lamp, 30min efficient removal of mites, 30M remote control, air purifier, formaldehyde filterCATWY Portable Adjustable Pet Wheelchair Dog Cart (XXXSXXL), Back Height 1375 Cm, Weight 1.560 Kg, Rear Leg Repair, Lightweight Aluminum Alloy, Available in a Variety Of Sizes (Size L02) 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, B LXF Pet travel stroller Pet stroller folding cart pet supplies Easy folding with removable pad, storage basket (color C)the parties commit to:60PCs blueeRed Striped Dog Collars Handcrafed Bow Tie Adjustable Detachable for Small Medium DogBlack2 Haoyushangmao Cat Bowl, Cat Food Bowl, Dog Food Bowl, Pet Supplies, Ceramic Bowl, Cat Feeder, Dog Food Bowl, Best Gift Latest Models (color Black and White) “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.Adjusting pet wheelchair Adjustable wheelchair dog travel trolley case pet portable out cart multifunction folding box (color Pink)ANDRE HOME Dog Bowl Cat Bowl Creative Solid Wood Dining Table Ceramic Tilt Double Bowl

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, color02 50\BelleAckerman Beach Blanket,Aquarium,Siamese Fighting Betta Fish Swimming in Aquarium Aggressive Sea Animal,Sky bluee Dark Coral,300GSM, Super Soft and Warm, Durable 50 x70 CAMP 3050lbsPetmate 21167 Pet Porter 2 Fashion Kennel, Large, Deerwas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.bluee ACvthfyky Foldable Cat Tunnel Channel Rolling Cat Litter Plushs Toy Suitable For Cats And Dogs (color Yellow1, Size H)2PACK OF LRG BOWLS Basis Pet Made in The USA Stainless Steel Dog Bowl, Medium (4.5 Cups), 4 Pack.

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. Canvas Wall Décor Diy Full Drill 5D Diy Diamond Painting Fishing Animal Embroidery cross Stitch Rhinestone Mosaic Painting Gift Full Drill Arts Craft Wall Sticker , Ibuprofen , 5575CM(21.6529.53iThe 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. A 60x45x15cmBiuTeFang Pet Bolster Dog Bed Comfort Pet Cushion Mattress Kennel Dog bed dog sofa mat mat removable nest cushion cat NestAzure Sky P515 Cat House Tower Rattan Furniture Tent, WhiteBarking Heads Dry Dog Food Fish 'n' Delish 100% Natural Salmon and Trout with Hypoallergenic Ingredients, GrainFree Recipe, 12 kgLast 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.