Millers' Indemnity Underwriters v. Braud

Background

A woman sought compensation under Texas’s workmen’s compensation law after her brother, a diver employed by the National Ship Building Company, died on April 17, 1920. He submerged from a floating barge anchored in the navigable Sabine River thirty-five feet from the bank to saw off timbers of an abandoned ship-launching structure that obstructed navigation. While underwater his air supply failed and he suffocated. The employer carried an insurance policy with the party that appealed the case; that insurer was treated as the statutory 'subscriber.' The Texas statute made the association the exclusive source of recovery for employees and their beneficiaries, and the deceased had not given any written notice to opt out.

Reasoning

The Court addressed whether the death should be governed by maritime law or by the state compensation statute. It explained that when a local regulation does not materially prejudice the essential features of general maritime law, a state may modify or supplement rights between the parties. Citing a prior case with similar facts, the Court found this to be a matter of local concern and held that the Texas law’s exclusive compensation remedy applies and therefore bars a separate admiralty tort claim. The Court noted other situations where state regulation would be improper, but those were not present here.

Real world impact

The decision upholds the lower court’s award and means that in similar local work deaths occurring on navigable waters, injured workers or their families may be limited to state workers' compensation benefits instead of suing in admiralty for damages. Employers and insurers operating in such local contexts will rely on the state compensation system as the exclusive remedy.