Parker v. Motor Boat Sales, Inc.

Background

George Armistead, an employee of a boat and motor seller, drowned when a motorboat capsized while testing an outboard motor on the James River. He was riding with a co-worker who navigated the boat. The Deputy Commissioner of the federal Employees’ Compensation Commission found the death arose out of employment on navigable waters and ordered the employer to pay benefits to the widow and three minor children. The District Court upheld that award, but the Circuit Court of Appeals reversed, finding the employee was not acting in the course of his work and suggesting state law might cover the death.

Reasoning

The Court examined whether the Longshoremen’s and Harbor Workers’ Act applies when an employee dies on navigable waters while engaged in a maritime activity. It found sufficient evidence that Armistead was acting in the course of his employment that day and that the Act expressly covers employees working in whole or in part on navigable waters. The Court interpreted the statute’s proviso about state compensation to mean Congress intended federal coverage in the field the earlier Jensen line of cases had taken from state control. The Court also rejected the late challenge to the widow’s capacity to file, noting the employer had not raised that objection earlier.

Real world impact

The decision means deaths that happen during clearly maritime work on navigable waters can be covered by the federal Longshoremen’s Act even if the worker normally did other land duties. Employers in similar situations face federal claims for compensation, and widows and children may receive benefits under the federal scheme. The Court reversed the appeals court and affirmed the District Court’s enforcement of the award.

Dissents or concurrances

The opinion notes earlier Supreme Court cases on maritime versus state authority produced sharp dissents, but the Court did not reopen those constitutional questions here; it used those cases only to mark the field Congress intended to cover.