San Diego Law Review

Library of Congress Authority File


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This comment examines Robinson v. Pocahontas, Inc., in which the First Circuit allowed punitive damages as a result of a ship owner's refusal to provide an injured seaman with maintenance and cure, and punitive damages for maritime torts in general. The author begins by stating the facts of Robinson v. Pocahontas, Inc. The author then discusses the legal foundation for the case which was Justice Stewart's dissenting opinion in Vaugh v. Atkinson. Next the author addresses punitive damages in admiralty, breach of contract actions, tortuous breach of contract actions, and under the Jones Act. The author concludes that the decision in Robinson was the correct decision and the case will most likely be followed in the future.

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