cases cited therein. 25 . Townsend, 129 S.Ct. at 2575 n. 12. 26 . Wagner v. Kona Blue Water Farms, LLC, No. 09-00600, 2010 WL 3566730 at *7 (D.Hi. Sept. 13, 2010). The court specifically did not address whether punitive damages were a viable remedy under the general maritime law cause of action for unseaworthiness. See Footnote 1 therein. 27 . Id. 28 . Id. at *7-8. 29 . See, e.g., Seaman v. Seacor Marine LLC, No. 07-3354, 2008 WL 360783, at *2 (E.D.La. Jan. 17, 2008) ("In this circuit, punitive damages are classified as non-pecuniary in nature .... Therefore, as a Jones Act seaman Plaintiff cannot recover them.”); Anderson, 797 F.Supp. at 534 ("[T]he post-Miles district court cases, in this distri on” in the Gulf of Mexico, MDL No. 2179, 2011 WL 4575696, at *11 (E.D.La. Oct. 4, 2011) (<HOLDING>). 31 . See, e.g., Rogers v. Resolve Marine, No.
holding that punitive damages do not need to be proportional to compensatory damages holding that seamen do not have a remedy of punitive damages for personal injuries but nonseamen do holding that personal disputes do not constitute persecution holding damages do not constitute other equitable relief holding a court may not award punitive damages