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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.. ____ RED Large RED Large Dog Leash Large Dog Explosion-Proof gold Wool Chest Strap Dog Leash Dog Chain (color RED, Size L)Red Large Red Large Dog-Assisted Belt with Handle Dog Hind Leg Disabled Power Repair Harness Limb Weakness Young Senior,Red,L(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, Red Large Red Large High Back Bow Pet Princess Bed Oval Pet Princess NestRed Large Red Large Luxury Cozy Cave Large Redparticularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Red Large Red Large Pawsitive Pet Reflective Nylon Martingale Collar Premium Nylon Adjustable Training Collar for Dogs We Donate a Collar for Every Collar Sold.Red Large Red Large Pet nest Oxford cloth PP cotton soft suitable for cats, dogs, small animals, etc. (color RED, Size L).

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. Red Large Red Large Puppy Dog Waterproof Motorcycle Clothing Printing Thick Warm Breathable Pet Autumn and Winter Casual Jacket Autumn and Winter,2 colors,5 Sizes,Red-LRED Large RED Large Square Non-Stick Hair Resistant to Bite Slip Haiming (color RED, Size L)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. Red Large Red Large YQQ Pet Bed Kennel Cat Nest Sleeping Pad Washable Nylon PP Cotton Four Seasons (color RED, Size L)Red Large 30-Inch Red Large 30-Inch VirChewLy Indestructible Traffic Lead for Dogs, 30 , Large, RedThird, 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 Red L-XFLX Pet Carrier,Cat Dog Puppy Travel Hiking Camping Pet Carrier Backpack, Space Capsule Bubble Design,Waterproof Soft-Sided Handbag Backpack for Cat and Small Dogs (color Red).

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. Red M Baosity Pet Carrier Backpack for Small Cats Dogs Outdoor Travel Carrier for Walk, Hiking, Cycling Red MRed M Red M BINGPET BB5001 Soft Mesh Dog Harness Pet Walking Vest Puppy Padded Harnesses Adjustable, Red MediumThe 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 Red M Red M Dog Coat Hoodie Dog Clothes Thicken Horn Button Red bluee Cotton Costume for Pets Men's Women's Keep Warm Fashion(M,Red) Red S Red S Dog Lead Dog Harness for Large Medium Dog Adjustable Soft Predictive Nylon Walking Pet Harness Dog Training Leash (color Red, Size S)Red S Red S Huayue Pet Hooded Sweater Dog Camouflage Spring and Summer Fooling T-Shirt (color Red, Size S)that 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. Red M Red M FidgetKute 2017 Comfortable Pet Dog Cat Sofa Bed House Cushion Mat Mat Pad House Cushion Red MRed M Red M Huayue Pet Dog Vest Comfy Breathable Dog T-Shirt (color Red, Size M)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,Red M Red M Kennel, Large, Medium and Small Pet Supplies, Warm Dog Bed Thickened Cat Litter Kennel (color Red, Size M)Red M red M Muziwenju Kennel, Teddy Pug, Kennel Washable, Four Seasons Universal, Special Kennel, Winter Warm Dog Bed, Pet Nest, (color Red, Size M) 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, Red M red M WANGXIAOLIN Pet nest, cotton, kennel, fully removable and washable, dog bed, high rebound, no static, pet sofa, thick warm, breathable (4 sizes) (color RED, Size M)the parties commit to:Red Sit Stay Cape Style Vest with Pockets- Service Dog, Therapy Dog or Emotional Support Dog, Reflective, Hand Sewn in USA (Red, Tiny)RED Small RED Small Chest Strap pet Adjustable Small Dog Chest Strap (color RED, Size 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.RED M(44cm) RED M(44cm) Dog Vest Harness, Plush Chest Strap Suitable for Small Dogs Vest Teddy Leash Adjustable Traction Outdoor Training Running Safety Buffer Pet Supplies (color RED, Size M(44cm))Red M fit for dogs 5.5-7.7Lb Red M fit for dogs 5.5-7.7Lb Dog Winter Sweater, Pet Knitwear Tutleneck Dog Apparel, Solid color Puppy Sweatshirt Clothes Dog Wool Classic Warm Soft Sweaters for Cold Weather, Puppy Warm Winter Coat for Small Medium Large Dogs

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, Red Small Red Small Kennel Dog Mat Pet Supplies Sleeping Mat Law Fighting Mats Removable and Washable Puppy Dog Winter Seasons Universal Winter (color Red, Size S)Red Small Red Small Pety Pet Fashion Flower Pattern Adjustable Pu Leather Pet Collars for Cats Puppy Dogs (Small, Red)was laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.Red Medium Red Medium Amosfun Womens Mexican Fiesta Dress Costume Dress Fancy Ball Halloween Party DressRed Medium Red Medium Dog Clothes Cosplay Pet Life Jacket Pet Transforming Clothes golden Hair Labrador Border Collie,Red,M.

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. Red Soft and Comfortable Foldable Dog Bed Room Cat Toilet Outdoor Portable Sleeping Bag Pet cat Dog cave Removable and Washable Four Seasons Universal (color Red)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. Red THERAPY DOG L Fits Girth 23 \ Red THERAPY DOG L Fits Girth 23 \ FidgetGear Mesh Dog Vest Reflective Label Patches in Training Service Therapy Dog Harness Red L Fits Girth 23 28 RED Medium RED Medium Kennel Pads Dog Beds Pet house Pet mat-Dog mat Dogs Bed Pet Bed For Cats Small Medium Large Dogs Cooling Mat Best Pet Supplies Four Seasons Universal @ (color bluee, Size L) Cat Bed Pet Supplies CRed Medium Red Medium Pet Dog Leash Retractable Dog Rope Cushioning Shock Free Hands For Medium And Large Dogs Four colors Optional KGMYGS (color Red, Size M)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.