The Dutra Group v. Batterton case in 2018 revolved around a dispute between Christopher Batterton, an employee of The Dutra Group, and his employer. Batterton had been injured on the job due to alleged unseaworthiness of the vessel he was working on and sought punitive damages from The Dutra Group. However, the U.S Supreme Court ruled against him stating that maritime law does not allow for recovery of punitive damages under an unseaworthiness claim. This decision was based on previous rulings which limited recoverable damages to those that compensate for actual harm suffered by plaintiffs rather than punishing defendants' conduct.

In the dissenting opinion for The Dutra Group v. Batterton, Justice Gorsuch argued that punitive damages should be available to seamen in personal injury suits against their employers. He contended that the majority's decision was not rooted in historical practice or precedent and instead relied on policy considerations better left to Congress. According to him, there is a long history of courts awarding punitive damages in general maritime law cases, including those involving unseaworthiness claims by sailors against ship owners. Furthermore, he disagreed with the majority's assertion that allowing such awards would disrupt uniformity with other federal laws limiting remedies for injured workers because these laws do not apply at sea where traditional maritime rules govern.