P worked as a deckhand and crew member on vessels owned and operated by D. While working on a scow P was injured when his hand was caught between a bulkhead and a hatch that blew open as a result of unventilated air accumulating and pressurizing within the compartment. P sued D for negligence, unseaworthiness, maintenance and cure, and unearned wages. P also sought punitive damages. D moved to strike the claim for punitive damages, arguing that they are not available on claims for unseaworthiness. The District Court denied D’s motion. The Court of Appeals affirmed. D appealed.