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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.. ____ 40 pound Lyric Supreme Wild Bird Mix 40 lb bagBlack HU Pet Trolley Polyester Production Light Waterproof Breathable One Button Storage Convenience Simple (color Black)(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, Baby bluee 3X-Large Baby bluee 3X-Large Mirage Pet Products Scribbled Merry Christmas Screenprint Pet Hoodies, 3X-Large, Baby blueeDean and Tyler SIMPLICITY+ , Dog Collar with Handle and Chrome Plated Steel Hardware Tan Size 86cm by 4cm Fits Neck 81cm to 91cmparticularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Double Bowl dkDaKanl Elevated Pet Feeder Double Raised Stand from Bamboo Wood,Dog Cat Food Station Feeder with Ceramic Feeding Bowls for Puppy Kitten (Double Bowl)Grey Pet Nest Non-slip Foldable Soft Four Seasons Dual-use Washable Bed Sleeping Bed Dog Cat Cave Bed House With Removable Cushion 111 84 81cm,Grey.

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. M- 6' BESSIE AND BARNIE Deluxe Strong Rainbow Blocks Nylon Dog Pet Durable Adjustable Leash (Multiple Sizes)402450cm Step Stool Step Stools 2 Step Step Stool Kitchen Wood Ladders Small Stool Indoor Portable Flower Rack Step Stool (Size 40 24 50cm)Second, 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. E Medium E Medium Retro Wall Tiles Dog Bed, Washable Pets Cats and Dogs Dual-Use Pads Metal Zipper Non Slip Pet Products S M L,E,MKESS InHouse Dawid ROC Camouflage Pattern 2 Multicolor Abstract Dog Bed, 30 x 40 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 Aquaforest Media Reactor Diameter 90 mm Height 30 cm Connection Pipe 16 mm 1.6 liters.

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. DIYthinker Christmas colorful Elk Lattice Festival Anti-Slip Floor Pet Mat Square Home Kitchen Door 80Cm GiftBwogue Bird Perch,Natural Grapevine Bird Cage Perch for Parred Cages ToyThe 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 Culpepper Charcoal Equine Couture All Purpose Saddle Pad Horse Riding Equestrian Saddle Pad Size- Standard Ibañez Folding Dog Cage 2019 (124 x 76 x 84 x (H) cm)DIYthinker colorful City France Painting Anti-Slip Floor Pet Mat Square Home Kitchen Door 80Cm Giftthat 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. CZHCFF Hot fashion animal summer cool waterproof cloth cushions bed Mats Dog house soft cooling surface sleeping matsKess InHouse Rosie Brown Autumn Breeze Fleece Dog Bed, 50 by 60 , orange RedThe 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,Kelato Zanobolic Concentrate 9kg (WKZBC9)Large Magnetic Aquarium Fish Tank Cleaner, Floating Glass Algae Remover Scrubber Scraper Brush for 0.59 inch or 15 mm Glass Thickness, Grey bluee 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 Pet Scissors, 7.5 Inch Straight Shears, Dog Grooming Scissors, Pet Grooming Shears Made of Stainless Steal (color Black)the parties commit to:Maroon XL Maroon XL KONG Reflective Dog Collar by Barker Brands Inc. (XL, Maroon)Dean & Tyler Sputnik Dog Leash with Brown Stainless Steel Ring on Handle and Herm Sprenger Hardware, 5-Feet by 3 4-Inch “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.1.0cm×120cm+1.0×23-34cm,bluee Pet Online Hyena rope nylon elastic buffer pet leash,1.0cm×120cm+1.0×23-34cm,blueeEzyDog Null Shock Couplers Double Lead Attachment Red

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, DIYthinker Classical Skeleton Chat Emoji Anti-Slip Floor Pet Mat Square Home Kitchen Door 80Cm GiftClearTronic 9 Watt Pet's House OASE INDOOR CLEAR TRONIC UVC AQUARIUM CLARIFIER ULTRA purple STERLIIZER FISHwas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.MarineLand Maxi-Jet PRO Impeller Assembly MJ600 by MarineLandCheetah Teal Collar, Teal, XS.

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. BROWN Diameter 62cm BROWN Diameter 62cm Pet Bed Small Dog Pet Bed Dog Mat Pet Mat Pet Sleeping Pad Pet Cat Dog Nest Cooling in Summer Pet SuppliesThe 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. Baosity Fertilizer Injector Dispenser Proportioner Injector for Livestock Agriculture 25 mmFour Paws Four Paws Magic Coat Essential Oil Avacado Shampoo, 16 ozKess InHouse Amanda Lane Pink and orange Mgoldccan Pet Bowl, 7-Inch, Magenta TangerineLast 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.