447 U.S. 715 (1980), 79-343, Sun Ship, Inc. v. Pennsylvania
|Docket Nº:||No. 79-343|
|Citation:||447 U.S. 715, 100 S.Ct. 2432, 65 L.Ed.2d 458|
|Party Name:||Sun Ship, Inc. v. Pennsylvania|
|Case Date:||June 23, 1980|
|Court:||United States Supreme Court|
Argued April 14, 1980
APPEAL FROM THE COMMONWEALTH COURT OF PENNSYLVANIA
Held: A State may apply its workers' compensation scheme to land-based injuries that fall within the coverage of the Longshoremen's and Harbor Workers' Compensation Act (Act), as amended in 1972. Pp. 717-726.
(a) Under the law governing jurisdiction over marine-related injuries before 1972, nonlocal maritime injuries fell under the Act, "maritime but local" injuries "upon the navigable waters of the United States," 33 U.S.C. § 903(a), could be compensated either under the Act or under state law, and injuries suffered beyond navigable waters -- albeit within the range of federal admiralty jurisdiction -- were remediable only under state law. Cf. Davis v. Department of Labor, 317 U.S. 249; Calbeck v. Travelers Insurance Co., 370 U.S. 114; Nacirema Operating Co. v. Johnson, 396 U.S. 212. [100 S.Ct. 2434] Pp. 717-719.
(b) The extension of federal jurisdiction landward beyond the shoreline of the navigable waters of the United States under the 1972 amendments of the Act supplements, rather than supplants, state compensation law. The language of the 1972 amendments cannot fairly be understood as preempting state workers' remedies from the field of the Act, and thereby resurrecting the jurisdictional monstrosity that existed before the clarifying opinions in Davis, supra, and Calbeck, supra. Nor does the legislative history suggest a congressional decision to exclude state laws from the terrain newly occupied by the post-1972 Act. Pp. 719-722.
(c) The disparities which Congress had in view in amending the Act lay primarily in the paucity of relief under state compensation laws, and concurrent jurisdiction for state and federal compensation laws is not inconsistent with the amendments' policy of raising awards to a federal minimum. Even though, if state remedial schemes are more generous than federal law, concurrent jurisdiction could result in more favorable awards for workers' injuries than under an exclusively federal compensation system, there is no evidence that Congress was concerned about a disparity between adequate federal benefits and superior state benefits, the quid pro quo to employers for the 1972 landward extension of the Act being simply the abolition of the longshoremen's unseaworthiness remedy. Nor does the bare fact that the federal and state compensation
systems are different give rise to a conflict that, from the employer's standpoint, necessitates exclusivity for each system within a separate sphere, since, even were the Act exclusive within its field, many employers would be compelled to abide by state-imposed responsibilities lest a claim fall beyond the Act's scope. Pp. 723-726.
41 Pa.Commw. 302, 398 A.2d 1111, affirmed.
BRENNAN, J., delivered the opinion for a unanimous Court.
BRENNAN, J., lead opinion
MR. JUSTICE BRENNAN delivered the opinion of the Court.
The single question presented by these consolidated cases is whether a State may apply its workers' compensation scheme to land-based injuries that fall within the coverage of the Longshoremen's and Harbor Workers' Compensation Act (LHWCA), as amended in 1972. 33 U.S.C. §§ 901-950. We hold that it may.
The individual appellees are five employees of appellant Sun Ship, Inc., a shipbuilding and ship repair enterprise located on the Delaware River, a navigable water of the United States in Pennsylvania. Each employee was injured after the effective date of the 1972 amendments to the LHWCA while involved in shipbuilding or ship repair activities. Although the LHWCA applied to the injuries sustained, each appellee filed claims for benefits under the Pennsylvania Workmen's Compensation Act with state authorities. Appellant contended that the federal compensation statute was the employees' exclusive remedy. In upholding awards to
each appellee,1 the Pennsylvania Workmen's Compensation Appeal Board ruled that the LHWCA did not preempt state compensation laws. The Commonwealth Court affirmed, and the Supreme Court of Pennsylvania denied petitions for allowance of appeal. We noted probable jurisdiction, 444 U.S. 1011 (1980), and affirm.
The evolution of the law of compensation for workers injured in maritime precincts is familiar. In 1917, Southern Pacific Co. v. Jensen, 244 U.S. 205, declared that States were constitutionally barred from applying their compensation systems to maritime injuries, and thus interfering with the overriding federal policy of a uniform maritime law. Subsequent decisions invalidated congressional efforts to delegate compensatory authority to the States within this national maritime sphere. Knickerbocker Ice Co. v. Stewart, 253 U.S. 149 (1920); Washington v. W. C. Dawson & Co., 264 U.S. 219 (1924). At the same time, the Court began to narrow the Jensen doctrine by identifying circumstances in which the subject of litigation might be maritime yet "local in character," and thus amenable to relief under state law. Western Fuel Co. v. Garcia, 257 U.S. 233 (1921); Grant Smith-Porter Ship Co. v. Rohde, 257 U.S. 469 (1922). And, in 1927, Congress was finally successful in extending a measure of protection to marine workers excluded by Jensen by enacting a federal compensation law -- the Longshoremen's and Harbor Workers' Compensation Act, 33 U.S.C. § 901 et seq. That statute provided, in pertinent part, that
[c]ompensation shall be payable [for an injury] . . . occurring upon the navigable waters of the United States . . . if recovery
through workmen's compensation proceedings may not validly be provided by State law.
44 Stat. 1426.
Federal and state law were thus linked together to provide theoretically complete coverage for maritime laborers. But the boundary at which state remedies gave way to federal remedies was far from obvious in individual cases. As a result, the injured worker was compelled to make a jurisdictional guess before filing a claim; the price of error was unnecessary expense and possible foreclosure from the proper forum by statute of limitations. Davis v. Department of Labor, 317 U.S. 249, 254 (1942). After a decade and a half during which there had not been formulated "any guiding, definite rule to determine...
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