This presentation will lay out the development of seamen's remedies, including the roles of Congress and the courts in formulating those remedies before discussing how the Fifth and Ninth Circuits set the state for resolution of punitive damages in seaman's unseaworthiness claims with McBride and Batterton. Finally, the Supreme Courts resolution in Batterton and what comes next. How will the lower courts apply Batterton? What does Batterton mean for seamen trying to recover punitive damages from third parties in negligence actions brought under the general maritime law? And what does the case mean for other maritime workers, or for passengers or pleasure boaters?