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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.. ____ Green 6350cm Green 6350cm Pet Cool mat Pet Cool Pad Dogs Mat Bamboo Double-Sided Breathable Summer Waterproof Mattress Kennel Cats Cooling Pad Sleeping Pad bluee Green orange pet Cool pad (color Green, Size 6350cm)bluee ZiJieShiYe New pet space bag breathable out portable backpack multi-function pet bag trolley case (color bluee)(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, JIAHUADE Couple Decoration Wedding Proposal Moss Micro Landscape Resin Decoration Bride and Groom Small Decoration CraftsCamo Grey XXXL Camo Grey XXXL Yu-Xiang Large Dog Raincoat Pet Strip Reflective Waterproof Costume Dogs Raining Jacket Poncho Hoodies (XXXL, Camo Grey)particularly those in the Merchant Marine Act of 1920 (Jones Act), under which only compensatory damages were recoverable.ELIVE 034111 Betta Bubble with Led Light White, 18.9l4wire Animal Run 6ft x 6ft 16G Strong Fox Dog Proof Cat Safe Enclosure Mesh Roof.

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. Hamilton Single Thick Dog Leash with Ribbon Overlay, 5 8 x 6', American PatternDean and Tyler GAIA Dog Collar With Brass Buckle Black Size 46cm By 5cm Width. Fits neck size 16 Inches to 20 Inches.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. DOGPRO Game ON 20KG (DDGO20)Extra Large 10.25\ Ideal Pet Products 3-Panel Airseal and VIP Pet DoorReplacement Flap, Extra Large, 10.25 x 15.75 Flap SizeThird, 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 L-02 YAXIAO Pet Car Suitable for Pets Hind Legs Practice Rehabilitation Limb Disability Support Walking Large Small Dog Adjustable 4 Rounds Pet car seat (Size L-02).

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. 50-90 lbs Aspen Pet Ruff Hauz Off Set Door, 50-90-Poundcolor08 L35.4\ color08 L35.4\ Jiahong Pan Decorative Aquarium Treasure Design Pirate Theme Fictional Aquarium Sticker Wallpaper Decoration L35.4 x H19.6The 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 bluee L bluee L WANGXIAOLIN Dog Bed, Cat Nest, Pet Supplies, Semi-Closed Cat Litter, Doghouse, Four Seasons (color bluee, Size L) 60CMX40CM BLWX-Pet mat Cat Cat Dog Rattan Cat Litter Kennel Mat Mat Pet Mat Summer Cool Mat Kitten Mat Dog Mat Cat Mat Pet mat (Size 60CMX40CM)Beige 454848cm Beige 454848cm LDFN Bite-resistant Dog Nest Washable Four Seasons General Pet Mattress Sofa Cushions,Beige-454848cmthat 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. (500 Watts) Finnex Digital Touch Control Aquarium Titanium Heater with Guard5XL SELMAI Large Dog Pumpkin Costume Pet Halloween Party Costume Fleece Dog Hoodie Jumpsuit Outfit Warm Autumn Winter Coat Clothes Size 5XLThe 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,Bowsers Donut Bed, Medium, PebbleD 503815cm D 503815cm WUTOLUO Pet Bolster Dog Bed Comfort Arctic dog Bed dog cushion pet nest (color D, Size 50 38 15cm) 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, 8piecesoffence+onedoor Freestanding Foldable Pet Dog Fence, Over Fence, Pet Small Courtyard, Doorway, Stairs, Extra Wide, Whitethe parties commit to:Cat tree for large cats Devon Rex Light Grey XXL extra big breed trees scratch post and adult towers Furniture scratcher activity centreAxiba Play Towers Trees for Cats Three layer cat climbing frame cat tree cat grab pillar cat nest for game 40cm 20cm 20cm “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.Black black 155 cm black black 155 cm PFIFF Outdoor Horse BlanketCOUNTRY HERITAGE Organic COARSE Layer 20KG(Grain Mix) (POCL20)

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, Black Large Black Large Prefer Pets 312LUX-BK Hideaway Duffle Pet Carrier, Deluxe, BlackBrown rentongye Grid Dog Potty,Dog Toilet, Puppy Cat Pet Training Mat Potty, Easy To Clean And Hygienic,Sterile,Tasteless And Corrosion Resistant,Suitable For Small and medium sized dogswas laid amending the Climate Change Act 2008 so that ‘80%’ is replaced by ‘100%’.Buckle-Down Seatbelt Buckle Dog Collar Penguins w Cupcakes Fuchsia Multi color 1 Wide Fits 11-17 Neck MediumBuckle-Down Marvel Comics 5 Black Dog Leash, 6'.

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. 60X60cm DIYthinker Cuba National Flag North America Country Anti-Slip Floor Pet Mat Round Bathroom Living Room Kitchen Door 60 50Cm GiftThe 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. Heart Pattern 2 Bowls Heart Pattern 2 Bowls Creation Core Solid Bamboo Elevated Pet Dinner Feeder for Small Dogs and Cats Raised Stand with Two Ceramic BowlsCoffee Beans Stainless Steel Pet Dog ID TagCat Tunnel Double Polyester Material Cute Wave Point Resistant to Grab Easy to Clean 140cmLast 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.