On August, 8, 2019, Sarah Yantakosol Gayer presented at the U.S. Court of Appeals for the Ninth Circuit in San Francisco, California. Specifically, Sarah presented the chapter she authored, "Punitive Damages under General Maritime Law and Ancillary State Matters" of the soon to be released American Bar Association treatise, Damages Recoverable in Maritime Matters, Second Edition (2019). She addressed what punitive damages are, when punitive damages are recoverable under general maritime law, the important limits on recovering punitive damages, and the three most important U.S. Supreme Court cases addressing the availability of punitive damages in maritime matters: the 2008 case of Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008), the 2009 case of Atlantic Sounding Co. v. Townsend, 557 U.S. 404 (2009), and the June 24, 2019 case of Dutra Grp. v. Batterton, 139 S. Ct. 2275 (2019).
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