Minnie v. Port Huron Terminal Co.

Background

A longshoreman working at Port Huron was unloading a vessel when a swinging hoist struck him and he was thrown onto the wharf. He filed for benefits under Michigan’s compensation law. His employer, the Port Huron Terminal Company, argued the accident happened on navigable water and that Michigan’s law therefore did not apply. The state commission awarded compensation, but the Michigan Supreme Court vacated that award, holding federal law controlled, and the U.S. Supreme Court granted review.

Reasoning

The central question was whether the claim should be decided under state compensation law or under federal maritime law. The Court explained that when the blow that causes the injury occurs on a vessel in navigable water, the resulting cause of action is maritime in character. The fact that the worker was later thrown onto the wharf does not change that. The opinion relied on earlier cases distinguishing injuries that arise on land from those that arise on ships and noted a prior case that dealt with the opposite factual situation. A related decision the petitioner cited did not conflict with this conclusion. For those reasons, the Court held that federal maritime law governs this injury and affirmed the judgment below.

Real world impact

This ruling means injuries caused by events that occur aboard a ship are treated as maritime claims rather than state workers’ compensation claims. Longshoremen, dockworkers, employers, and state compensation boards will need to apply maritime law when the harmful event occurred on the vessel. The Court affirmed the lower court’s decision in this case.