Plaintiff Townsend was a crew member of the Motor Tug Thomas, a tugboat owned by Atlantic Sounding. After Townsend fell on the steel deck of the tugboat and injured his arm and shoulder, Atlantic Sounding refused to provide any medical treatment. As a result, Townsend brought a claim in Federal District Court, alleging that Atlantic Sounding violated its duties under "maintenance and cure," an aspect of federal maritime law which provides that the owner of a vessel must furnish food, lodging, and medical services to seamen injured while serving the ship. Townsend pursued punitive damages for what he argued was "willful withholding of maintenance and cure."

Before trial began, Atlantic Sounding moved to dismiss Townsend's punitive damage claim. While the United States District Court for the Middle District of Florida denied the motion, it certified the question for interlocutory appeal. Soon after, the Court of Appeals for the Eleventh Circuit affirmed, and once Atlantic Sounding appealed that decision, the Supreme Court affirmed as well.

First, the Supreme Court described how punitive damages have "long been an available remedy at common law for wanton, willful, or outrageous conduct." English juries were given broad discretion to award such damages since at least 1676, and this tradition was largely left unchanged during our nation's founding. The Court recognized that American courts have permitted punitive damage awards since at least 1784, and in the context of federal maritime law, courts have recognized the possibility of punitive damages since 1818.

Because punitive damages is such a well-established aspect of tort law, the Supreme Court held that nothing precludes its application in federal maritime claims unless Congress specifically enacts legislation that departs from the common law understanding. Atlantic Sounding argued that the Jones Act qualifies as such legislation, but the Supreme Court disagreed. While the Jones Act creates a statutory negligence cause of action for maritime torts, nothing in the Act eliminates preexisting remedies available to seamen for the separate common law cause of action based on maintenance and cure. The Jones Act, in other words, simply offers additional causes of action not previously available under common law.

The Supreme Court next turned its attention to Atlantic Sounding's second argument: that the Court, in Miles v. Apex Marine Corp., previously limited recovery of maritime claims to only the remedies available under the Jones Act. In Miles, the Supreme Court decided whether general maritime law should provide a cause of action for wrongful death based on unseaworthiness. The Court determined that by providing a remedy for wrongful death suffered on the high seas or in territorial waters, the Jones Act along with the Death on the High Seas Act ("DOHSA") displaced a general maritime rule that denied any recovery for wrongful death. Because no remedy for wrongful death previously existed, the remedy available in Miles was naturally limited to those Congress specifically provided for under the Jones Act and DOHSA. Maintenance and cure claims, on the other hand, is not a matter to which Congress has spoken directly. Because the claim existed at common law, and because nothing in either the Jones Act or DOHSA evinces general hostility toward recovery of punitive damages for failure to provide maintenance and cure, the Court held that such damages shall remain available for deserving plaintiffs.

Atlantic Sounding Co. v. Townsend thus preserves a plaintiff's right to recover punitive damages pursuant to the willful, wanton, or outrageous disregard of a defendant's maintenance and cure obligations. After denying Atlantic Sounding's motion to dismiss, the Court remanded the case to the United States District Court for the Middle District of Florida, giving Townsend the opportunity to prove his punitive damages claims.