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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.. ____ Green 3L Green 3L Sabart Pet Clothes Cold Weather Dog Vest For Large Dogs 4 colors ( color Green , Size 3L )4-Feet Casual Canine Bone Heads Dog Lead, 4-Feet, orange(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, 8W with EU plug Pukido LED Aquarium Fish Tank Fishbowl Slim Light Waterproof LED Light Bar SMD 4 5 6 8W LED Light Lamp Aquarium Led Lighting Lamps 220V (color 8W with EU Plug)Dosckocil Petmate DDS29534 Pet Step IIparticularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Bowser 16512 Super Soft Round BedB HLWAWA Cremation Urn for Ashes Pet And Human Ashes Creative Cover Horse Ancient Craft (color B).

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. KESS InHouse Laura Nicholson Kissing Budgies Geometric Beige Pet Bowl, 7 9XL Dog Raincoats Waterproof, Adjustable Waterproof Pet Dog Raincoat, Rain Jacket with Hood Collar Hole, Lightweight Packable Outdoor Dog Hooded Raincoat, Extra Small to Extra Large,9XLSecond, 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. Black XXL Black XXL Olwen Shop Dog Coats & Jackets Waterproof Pet Dog Clothes Coat for Small Dog Winter Puppy Jacket Warm Clothing Pet Products D655 1 PCsHiggins Sunburst Gourmet Rabbit Food Mix, 6 Lbs, LargeThird, 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 F.M. Brown S-Grocery 51186 Encore Hamster Gerbils Food 5 .

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. 131-138CM Stair gates Baby Gates Pressure Mount Baby for Doorway, Metal Self Closing Dog Gate for Pet, Wood Walk-thru Door, 75-166cm Extra Wide (Size 131-138CM)KESS InHouse Tobe Fonseca Spring Pattern Floral Red Black Red Mixed Media Pet Bowl, 7 DiameterThe 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 Creative Foraging Systems + E487 CFS Push and Pull Pet Feeder by Caitec Corp (English Manual) bluee Small bluee Small Outdoor Swimming Pool Bathing Tub Portable Foldable Ideal for Pets Small 32 x 8 Grey S 50x40cm Grey S 50x40cm Sex Appealing Warm Fleece Dog Bed Soft Sherpa Cotton Dog Mat Comfortable Solid Pet Bed for Dog and Cat Dog Kennel Drop Shipping,Grey,S 50x40cmthat 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. L Rockingtail Pet Teepee Portable Dog and Cat Tents Comfortable Cotton Non-Slip Washable Durable Tough Canvas Piglet PatternMartin Sellier 85102 Rubb N Roll Bone, 8 , MixedThe 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,Buckle-Down Seatbelt Buckle Dog Collar Red pinks Polka Dots Turquoise 1 Wide Fits 11-17 Neck MediumALEKO® DKSC5X5X4SQ Heavy Duty Dog Kennel 5X5X4 Foot Pet Playpen With Dark Green Shade Cover With Aluminum Grommets 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, Dog Chain, Small Dog Pet Dog Leash, Vest Strap Puppy Leash, Chest Strap, Teddy Cat Pet Traction, Cute Cat XL Code Bust About 42-48CM (color Flowery, Size S)the parties commit to:gold Pet Online Pet Collar with Diamond pu Leather Dog collargoldbluee S bluee S ZIOFV Package Camouflage Dog Cat Pet Sling Carrier Bag Portable Foldable Pet Shoulder Crossbody Bags “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.Flash Red Small 15-24inch chest Flash Red Small 15-24inch chest Dexil Elite Range Luxury Padded Waterproof Adjustable Back and Front Ring Non-Pull Small Pet Dog Vest Harness (Flash Red, Small 15-24inch Chest)Chocolate 12\ Chocolate 12\ Premium Leather Collars with Stainless Steel Buckles (12 -15 , Chocolate)

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, golden Wood Beaded Seat Cushion Summer Breathable Seat Cover Anti-Slip Car Interior Seat Chair Pad Cushion(One Pack)Auburn Leathercraft Silver Studded Collar 3 4 x 16 BLACKwas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.Brown-2 1 Brown-2 1 Dog shoes, Waterproof Non-Slip Pet Snow Boots Velcro Strap Wear-Resistant Oxford High shoes Winter Warm 4PCS Medium Small Dog Outdoor Sport shoes 2 color (color Brown-2, Size 1 )D 52CMX60CM D 52CMX60CM Xiao Jian- Pet Nest Kennel Removable And Washable Teddy golden Hair Thickened Dog Bed Large Dog Winter Puppy Dog Supplies pet bed (color D, Size 52CMX60CM).

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. color XINGZHE Pet travel bag, pet trolley case, large space, 360° redating wheel, breathable, safe, storage bag, portable cat and dog travel equipment Pet bag (color color)The 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. Black 133x145cm Black 133x145cm CEFULTY Super Soft Pet Oxford Cloth Trunk Car Mats Pad Waterproof Out Rear Seat Cushion Suitable for Dogs and Cats (color Black, Size 133x145cm)LFMZB Marvel Avengers Black Panther Action Figure, Black Panther Toy Height About 27cm 11 Inch1Pc Aquarium Fish Plant Air Valve Splitter 2 Row 8 Way OutletLast 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.