Kahumoku v. Titan Maritime, LLC

ORDER GRANTING TITAN MARITIME’S MOTION FOR SUMMARY JUDGMENT AS TO THE PLAINTIFF’S SECOND CAUSE OF ACTION (PUNITIVE DAMAGES)

SEABRIGHT, District Judge.

I. INTRODUCTION

The Plaintiff, Michael Kahumoku (“Plaintiff’), was injured in the course of a marine salvage operation. The Plaintiff filed a negligence claim against Defendant Titan Maritime LLC’s (“Titan”) for both compensatory and punitive damages. Titan filed for summary judgment on the grounds that punitive damages are not available under 33 U.S.C. § 905(b) or, in the alternative, that the facts of the case do not sustain a claim for punitive…