shoulder car take-on Teddy cage cat handbag slung bag travel dog bag cat portable out Pets F3 bag ZAQXSW F3) (color zcjb492111353-Backpacks

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.. ____ D S D S Lozse Pet Beds Kennel Coffee wave point pet nest two-sided pet bed Shu cotton velvet polar fleece face Oxford Noodles for Dogs and Cats Sleeping Cushion3 m3 m Yang Shade netting- 90% 2m3m Sun Mesh Shade Sunblock Shade Cloth UV Resistant Net with Strengthened Tape and Grommet (Size 3 m3 m)(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, L(45.5KG) Pet Carrier Backpack,Legs Out Front Dog Carrier, Hands-Free Adjustable Pet Backpack Carrier, Wide Straps Shoulder PadsBROWN Pet Nest Pet Sofa Pet Bed Cat Nest Kennel Dog Nest Cat Kennel Bowl Cat Claws Grinding Plate Corrugated Paper Haiming (color Brown)particularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.60x46x17cm Dog Nest, Dog Sofa,Comfortable and Breathable, Four Seasons Usable,Removable Washable, Anti-slip Teddy Kennel, for Small and Medium Large Dogs, Pet Nest, Dog Beds, bluee (Size 60x46x17cm)Brown fits for 23 inch dog's neck size Brown fits for 23 inch dog's neck size 23 inch Handcrafted Brown Leather Dog Collar with Chrome Plated Steel Hardware ‘Spaceman Style’ 1 1 2 inch (40 mm) Wide.

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. Green S Green S Pet Dog Bed Winter Warm Kitten Kennels Thick Soft Pet Nest Cat Sofa Puppy Mat Animals Pad Pet Supplies House for Small Large DogsKirkland Signature 42 (106.7 cm) Round Pet Bed, Beige DesignSecond, 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. 800 Dog Cat Poop Bags Pet Waste Litter Bags (Green) with EZ Dispenser3 mm 10 mm Tile Spacers for Patio Tiles, Floor TilesThird, allowing punitive damages would place Amer­ican shippers at a significant competitive disadvantage and discour­age foreign-owned vessels from employing American seamen

shoulder car take-on Teddy cage cat handbag slung bag travel dog bag cat portable out Pets F3 bag ZAQXSW F3) (color zcjb492111353-Backpacks

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 3 4\ Lupine 3 4-Inch Tail Feathers 4-Feet Dog Leash.

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. Kess InHouse Nicole Ketchum Bird Song Pet Bowl, 7-InchBuckle-Down DLS-W30840 Leash Splitter-Hot Rod w Flames, 1 W-30 LThe 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 Light Pink Size 20 Light Pink Size 20 Mirage Pet Products Sprinkles Dog Collar with Pearl and Light Pink Crystals, Size 20, Light Pink Donut Bed in Almond Fabric (Medium 35 x 27 x 8 in.)Concept for Life Sensitive Cats 10kgthat 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. FOR 2 DOGS Remote Dog Training Collar1200Ys Range, Rechargeable Pet Training Electric System Waterproof Dog Shock Collars with Vibration Beep Light Static Anti-Bark Pet Trainer (for 2 Dogs)bluee ROODO Pet Bowl Silicone Folding Dog Bowl Out Portable Dog Pot golden Edging Teddy Dog Bowl cat Pot Dog Supplies (bluee)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,12000 LPH Hozelock 1585 Aquaforce 12000 Pond PumpDIYthinker Graffiti Street Yellow bluee Black Woman Anti-Slip Floor Pet Mat Square Home Kitchen Door 80Cm Gift 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.

Light bluee M 605019cm Light bluee M 605019cm LITING Kennel Removable And Washable Four Seasons Universal Net Red Cat Litter Small Medium Dog Dog Winter Warm Pet Supplies (color Light bluee, Size M 60 50 19cm)56cm Soft Warm Pet Dog Cat Bed House Plush Cozy Nest Mat Pad Cushion Cave

shoulder car take-on Teddy cage cat handbag slung bag travel dog bag cat portable out Pets F3 bag ZAQXSW F3) (color zcjb492111353-Backpacks

gold Variable Speed Pet Grooming Hair Dryer, High Velocity Hairdryer Blaster Fur Blower with 2 Gear Temperature and Flexible Hose for dogs and catsHip Doggie NFL Bears Pet Hoodie, Medium

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, Evans Collars 1 2 Jeweled Collar, Size 14, Mini Chevron, Blackthe parties commit to:65cm x 50cm Dog Cat Pet Cooling Mat Heat Hot Weather Gel Pad Bed Self Cooling Dog Cool MatFidgetGear Dog Harness Set Pet K9 Harness+Leashes Police Tranining Safety Pull Collar bluee Set M “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.Buckle-Down Seatbelt Buckle Dog Collar Spider-Man Costume Stripe bluee Red Black 1.5 Wide Fits 13-18 Neck Small1900 GPH Tetra Pond Water Garden Pump, 1900 GPH

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, 75 Fast Fit Pet Patio Door with Extra Large 10 1 2 x 15 Flap (Mill (aluminum))Green Large green Large Large Pet Dog Bed Cushion House Puppy Cat Soft Warm Kennel Mat Washable Blanketwas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.KESS InHouse Strawberringo Dark bluee White Dog Bed, 50 x 40 18cm 7.09in Red Aquarium Lamp 5050 LED Aquarium Lighting Fish Tank Light for Amphilophus Fish 18-68cm 7.09-26.77in,18cm 7.09in.

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. Ceramic Base Fish Tank Artificial Decorating Aquarium Plant Aquatic Tri-colorThe 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. GREEN L GREEN L Meng pet Small Dog Iron Frame Ceramic Bowl Pet Supplies Dog Dish Rack Dining Table (color Green, Size L)12 Pack Lincoln Re-Elect For Horses & Ponies An Electrolyte Paste To Replenish Lost Salts Pack Of 12 Or SingleCeramic Base Plastic Aquarium Fish Tank Artificial Plant Ornament 39cm HeightLast 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.