Nogueira v. New York, New Haven & Hartford Railroad

Background

A freight handler employed by a railroad was injured while moving a bale of paper on a car float used to carry railroad cars. The float was lying in navigable waters at Pier 42 in the East River, New York Harbor. The handler sued under the Federal Employers’ Liability Act in federal court, but the District Court dismissed the complaint on the ground that the Longshoremen’s and Harbor Workers’ Compensation Act applied; the court of appeals affirmed.

Reasoning

The Court examined the Longshoremen’s and Harbor Workers’ Compensation Act, which provides compensation for employees engaged in maritime work who are hurt on navigable waters and makes that compensation the employer’s exclusive liability. The Act’s definition of employer and its coverage were broad enough to include a railroad company when its employees perform maritime work on navigable waters. The Court found no exception for railroad employees in the statute as passed, and it relied on the Act’s plain terms making compensation exclusive under section 5. Because the injury occurred on a vessel in navigable waters and state remedies could not validly apply, the federal statute governed and barred the Federal Employers’ Liability Act claim.

Real world impact

The decision means employees hurt while doing maritime work on vessels like car floats are generally limited to the compensation scheme Congress created under the Longshoremen’s Act instead of suing under the Federal Employers’ Liability Act. If an employer fails to secure required compensation, some limited legal remedies remain, but the Act’s exclusive framework controls recovery going forward.