The Eastern District - Judge Barbier - decided Hancock v. Higman, where passengers on a mud boat filed suit, alleging they were run over by a pushboat. Higman, trying to strike parts of the claim early, argued the facts as alleged were inadequate to find gross negligence and award punitive damages. The Court stated:
Here, Plaintiffs allege that the M/V Trinity's captain and the crew saw Darrell and Ethan Hancock in their mudboat, but that the ship did not slow down. The complaint alleges that M/V Trinity continued to bear down upon Darrell and Ethan Hancock, which caused them to evacuate the mudboat. At this stage in litigation, the Court is not prepared to declare that these allegations, taken as true, fail to state a claim for which punitive damages may be appropriate under maritime law.
In abject fairness, this is on Rule 12(c), which is an identical standard to Rule 12(b)(6). Still, hard to compare this to the Palin decision without coming away with the belief one court uses a very different "reckless" standard from the other.
And perhaps more distinctively, in Michigan, a district court in a Jones Act case ruled a plaintiff who was denied M&C for a certain time and lived (for free) with his father could still claim punitive damages despite a summary judgment motion. Without meaningful comment, the Court concludes:
Plaintiff is a 52 year old adult who claims he was forced to live with his father out of economic necessity. Plaintiff admits that he did not pay rent or utilities, but contends he had an agreement with his father to reimburse him for the support provided.
The court finds that there is an issue of fact whether defendants acted in bad faith with regard to the delay in paying maintenance benefits.
This gives rise to a reasonably interesting question: there is an argument, which I've never seen pressed, as follows. If a Jones Act seaman is improperly denied M&C, s/he is entitled to compensatory damages for the denial. Meanwhile, per Exxon v. Baker, punitive damages are capped at 1:1 the compensatory damages. The argument (which I think is accurate) is that the punitive damages for arbitrary and capricious denial of M&C should be capped at 100% of the compensatory damages for denial of M&C - not 100% of the total compensatory damages for the case.
Still, to press that issue, you'd have to find the right case, which nobody wants to be fighting on that territory anyway.