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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.. ____ A XX-Large A XX-Large Weiwei Pet Supplies Fashion Short Plush Skid-Proof Plastic Kennel Teddy Bear Pet NestKaytee Woodlands Wild Bird Food, 10-Pond(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, Brown 402323CM Brown 402323CM Outdoors Portable Pet Backpack Small Pet Outpacks EVA Oxford Cloth Car Pet Bag Foldable Mesh Ventilation (color Brown, Size 40 23 23CM)Fits for 33 inch (83cm) dog's neck size FDT Artisan 33 inch Pink Leather Dog Collar with Chrome Plated Decor Round & Spicy particularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Cat Tunnel Toy, Collapsible, Kitten Indoor Toys(Yellow)100g Fluke Solve Vetark Professional Fluke Solve, 100 g.

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. 2.5 kg JBL StabiloPond basis 2,5 kg, Basic care product for all garden pondsLFMZB Marvel Avengers Black Panther Action Figure, Black Panther Toy Height About 27cm 11 InchSecond, 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. Dean & Tyler DT Fun Works Harness, Border Patrol Dog, Black With Reflective Trim, Medium Fits Girth Size 28-Inch to 34-InchLarge 30\ Kess InHouse Catherine McDonald Japanese Cherry Blossom Fleece Dog Bed, 30 by 40-InchThird, 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 35w L@LILI Small Submersible Water Pump For Pond, Aquarium, Hydroponics, Fish Tank Fountain With 5.9Ft Power Cord,35w.

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. CXQ Puppies Cat Food Bowl Creative Cute Pink Pig Cartoon Cat Bowl Dog Bowl Pet SuppliesBac-AZap Odor Eliminator Gallon Nisus Odor Eliminator by NisusThe 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 FXQIN Professional Pet Hair Dryer Dog Grooming Blower With Heater, Noise Reduction & Stepless Adjustable Speed & 3 Different Nozzle (Black) KESS InHouse Cafelab Pastel Geometry Paech bluee Dog Bed, 30 x 40 Corner Biz Aquarium 40w 2000l h Fish Pond Aquarium Led Submersible Water Pump Garden Decoration Fountain Pump Led Light color Change Fountain Makerthat 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. INMOZATA Pet Ramp Dogs Skidproof Slope Height Adjustable Foldable Pet Ramp Pet Ladder Wood for Car Van Travel (100 40cm(LXW), H30-40-50-60cm)Aquarium Light Kits, Remote Control RGBW Adjustable 64 LED Bulbs Switch Aquarium Fish Tank Lamp Green Lighting (110V)The 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,DS- Pet stroller Pet Bag Car Seat Small Pet Car Bag Foldable Pet Anti-dirty Pad Pet Bag 360X360X240mm &&KESS InHouse Li Zamperini Like a pink Black White Dog Bed, 50 x 40 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, Black Light Pink Handle 6 Feet x 3 4 inch Black Light Pink Handle 6 Feet x 3 4 inch Soft Touch Collars Leather Braided Dog Leash with Padded Handle, Black and Light Pink 6 feet x 3 4 Inch, Great for Large Female Dogsthe parties commit to:Black Household Mosquito Killer Lamp, Ultra-Quiet No Radiation Electronic Mosquito Lamp, Pregnant Women Baby Indoor Insect Killer Lamp, Bug Zapper, White, Black, 20-50M2Buckle-Down MGC-W30877-WS Hibiscus Collage Purple Shades Martingale Dog Collar, Small “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.Dean & Tyler Dean's Legend Dog Collar with Brown Padding and Chrome Plated Steel Hardware, 28 by 1-1 2-Inch, BlackB L B L wfycwb Pet Bag Cat Bag Outdoor Travel Handbag Cat Nest Dog Bag Travel Bag Pet Transport Box Shoulder Bag Pet Cage Breathable

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, Ldlms Pet supplies Cat climbing cat litter cat tree large sisal pillar cat jumping cat furniture10 Stick(s) 5 Straight Bully Sticks for Dogs [Large Thickness] (10 Pack) Natural Low Odor Bulk Dog Dental Treats, Best Thick Pizzle Chew Stix, 5 inch, Chemical Freewas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.KESS InHouse Alison Coxon Ruby Mandala Red White Digital Dog Bed, 50 x 40 KESS InHouse Carolyn Greifeld Leaves of Dreams bluee Dog Bed, 30 x 40 .

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. 22 inch FDT Artisan 22 inch Brown Leather Dog Collar with Brass-plated Skulls and Plates Plates'n'Skulls Exclusive Handcrafted Item 1 1 2 inch (40 cm) wide Gift Box IncludedThe 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. MaxxPet Dog Joint and Hip Chews Natural Supplement Supports Joint Health Made in The USA Glucosamine Organic Turmeric Dried Yucca MSM Dog Chewable Treat 120 Soft ChewsA 45×60cm A 45×60cm PLDDY pet bed Pet Mat, Large Dog Kennel Cat House Removable And Washable Nest Wear-resistant Bite Pet Bed (color A, Size 45×60cm)AU Plug Fish Tank Lamp Waterproof Dimmable Aquarium Lamp 36LED White bluee Strip Light Bar with Stretchable Lamp Bracket for Uncovered Aquariums (AU Plug)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.