Law360, New York ( August 6, 2014, 11:03 AM EDT) -- In Sanchez v. Various Defendants, 2014 U.S. Dist. LEXIS 92959 (E.D. Pa. Jul. 9, 2014), the Multidistrict Litigation Court overseeing the federal asbestos docket recently held that punitive damages are unavailable to the estate of a deceased seaman seeking to recover such damages, whether under a wrongful death or survival claim, from a vessel-owner employer under a theory of unseaworthiness. In so holding, the court reasoned that suits prosecuted after the death of a sailor are governed squarely by the U.S. Supreme Court's decision in Miles v. Apex Marine Corp., 498 U.S. 19 (1990). The reasoning of Sanchez, and its application of the Miles uniformity doctrine, provides counsel for product manufacturers and suppliers in the asbestos litigation — who were not the plaintiff's employer — with a similarly strong argument that in cases brought under maritime law, punitive damages are likewise unavailable under theories of negligence or strict liability....