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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.. ____ bluee Medium bluee Medium Medium and Large Dog Dog Toilet Dog Toilet, Pet Supplies Dog Toilet, Size color OptionalBiuTeFang Pet Bolster Dog Bed Comfort Removable pet sofa cushion cat Nest Pet Nest(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, Dean & Tyler Seizure Alert Service Dog 18 by 21-Inch Patch Collar with 6-Feet Stainless Snap Padded Puppy Leash, Small, BlackCat Warmer Mat Pumpkin Style Soft Retractable Pet Dog Cat Cradle Sleeping Bed Mat Cushion Pad pink(Pink-L)particularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.Light tan M Light tan M Cat Kennel, cat House Small Dog Kennel, Warm cat and Dog mat (color Light tan, Size M)D X-Small D X-Small Raincoat Pet Dog Life Jacket,Dog Swimming Life Jacket Vest in Beach Pool Rowing Safety Swimwear (color D, Size XS).

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 Pet Bio Bag Dispenser and 2 Rolls Poop Bags by The Green Pet ShopMed Large Pen 36-Inch New World Pet Products B554-36 Foldable Exercise Pet Playpen, Black, Intermediate 24 x 36 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. Kess InHouse Catherine Holcombe Welcome to My World Feeding Mat for Pet Bowl, 24 by 15-InchC Kaxima Pet Carrier Backpack Pets out Pack Oxford cloth out Portable pet bag breathable doggy folding bag 46x23x35cmThird, 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 HUYP Cat Comb Dog Needle Comb Pet Cat Comb Cat Brush Comb Pet Products.

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. Huangyingui Pet Bed Cat Or Puppy S M L, Yellow (Size S-40 50 22cm)KESS InHouse Project M Pin Points Polka Dot Pink Black Dog Bed, 50 x 40 The 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 Amyove Breathable Space Capsule Backpack with Wood Perch for Pet Bird Parred L Wuwenw 1Pc Soft Sleeping Bag Fleece Pet Mat Winter Warm Nest Pet Cat Rabbit Puppy Dog Kennel Bed Coffee color,LKess InHouse Rachel Burbee I Need The Sea Typography Fleece Dog Bed, 50 by 60 , Pinkthat 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. Black Hunting Collar for Dogs Training, Range 2000Yds Dog Shock Collar with Remote Highlight LED Flashing, Waterproof and Rechargeable Duralble TPU Electronic Collars of Dogs7050cm YunYilian Pet Bolster Dog Bed Comfort Dog Cushion Cat Cushion Pet Litter Kennel cat nest Big Medium Sized Dog Bed (Size 70 50cm)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,Industrial Dog by SodaPup Natural Rubber Treat Pocket Fetch & Dental Chew Toy Yak Chew Holder Made in USA for Heavy Chewers Yellow Largebluee Small bluee Small CHEDE Luxury Real Leather Dog Collar- Handmade For Small Dog Breeds With The Finest Genuine Leather-Best Quality Collar That Is Stylish ,Soft Strong And Comfortable-bluee Dog Collar 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, DarkGreen Large DarkGreen Large Cat Carrier Top Opening Cat Dog Puppy Travel Hiking Camping Pet Carrier Backpack Cat Carriers Medium Foldable,DarkGreen,Lthe parties commit to:4XL Dog Raincoats Waterproof, Red Dog Raincoat, Waterproof Rain Jacket with Hood Collar Hole, Lightweight Packable Outdoor Dog Hooded Raincoat for Medium Large Breed Dog,4XLKess InHouse Matthias Hennig Floral Green Floral Geometric Pet Dog Blanket, 60 by 50-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.Fighrh Pet Fashion Environmentally Friendly Eating Bowl Cat Drinking Bowl Cat Pot Food Bowl to Predect The Cervical Spine Anti-Skid Adjustable Dog Bowl Cat Rice BowlBowsers Donut Bed, X-Small, River Rock

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, Lzour Dog Car Seat Cover Waterproof Scratch Proof Non-slip Back Seat Pet Predection Dog Travel Hammock 148cm X 138cm for All Cars180 Cm Pets-easy Circular Horse Sticker 10 cm x 60 cm dressage-cheval-t 180 cmwas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.HEXBUG Mouse Robotic Cat Toy (Grey)blueE S blueE S Waterproof LED Lighted Dog Collar and Leash, USB Rechargeable, 3 Sizes.

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. KESS InHouse Liz Perez Indigo Soul Pastel Multicolor Digital Pet Bowl, 7 DiameterThe 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. Dean & Tyler's DT Fun 100% Bitch Harness, X-Small, with 6 ft Padded Puppy Leash.Kess InHouse Jeff Ferst Sonoran Fantasy Red Abstract Fleece Dog Bed, 30 by 40 bluee Petmate 21930 Puppy 2 Door Training Retreat, 24-Inch, blueeLast 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.