Employers' Liability Assurance Corp. v. Cook

Background

Hal Cook, an employee of the Ford Motor Company who was available for any kind of work, was instructed to help unload a Ford-owned ship at the Houston dock. While working in the ship’s hold he was seriously injured and later died. Ford carried a workmen’s compensation insurance policy, and Cook’s family filed a Texas compensation claim that the State board denied as not incident to employment. The family sued in state court, the case moved into federal court, and a jury originally found for the family.

Reasoning

The Court focused on where and how the injury happened: Cook was injured while unloading a vessel afloat on navigable waters. Citing a prior decision about stevedores and the Jones Act, the Court held that national maritime law governs injuries arising out of ship unloading in navigable waters. Because that federal law occupies this field, the State lacked power to prescribe the rights and liabilities for this accident, and the earlier state-based award could not stand.

Real world impact

The decision means that accidents occurring while unloading ships on navigable waters are governed by national maritime law rather than by state compensation rules in cases like this. Employers do not lose federal protections simply by accepting a state compensation plan. The Supreme Court reversed the lower judgment and sent the case back for further proceedings consistent with its holding.

Dissents or concurrances

Justice Stone wrote separately, relying on the view that a worker unloading a ship is a seaman under the Jones Act and that Congress excluded state regulation in this area; Justices Holmes and Brandeis joined in concurrence.