On May 12, 2010, the United States District Court for the District of Massachusetts assessed punitive damages and attorneys' fees against a vessel owner as a result of the owner’s “callous, willful, or recalcitrant” failure to pay cure to a plaintiff seaman. Mulligan v. Maritrans Operating Co., Civil Action No. 06-10492-LTS (D. Mass., May 12, 2010) was the first such decision from a district court in the First Circuit (based in Boston) since the U.S. Supreme Court decided Atlantic Sounding Co. v. Townsend, 129 S. Ct. 2561 (2009) last year. In Atlantic Sounding, the Supreme Court confirmed that such punitive damage awards are permissible under the general maritime law in appropriate circumstances, as several U.S. Circuit Courts of Appeal, including the First Circuit, had previously held. Though such cases turn on their own facts, Mulligan offers some guidance as to circumstances that may trigger an award of punitive damages and attorneys' fees, knowledge of which is useful to avoid such an award.