Davis v. Department of Labor and Industries of Wash.

Background

A widow sued after her husband, a structural steelworker employed by a construction company, drowned while dismantling an abandoned drawbridge on the Snohomish River. The employer used a derrick barge and other licensed vessels to lower cut steel onto a barge where the worker was standing when he fell into the water. Washington’s workers’ compensation law normally covers employees in certain occupations, but the State’s highest court had held the law could not apply because the accident involved navigable waters and maritime law issues.

Reasoning

The central question was whether the Constitution prevented the State from paying compensation in this borderline waterfront case. The Court explained there is a long, confused line of earlier maritime decisions and a federal Longshoremen’s Act that governs some waterfront workers, but federal administrative findings carry special weight and were absent here. Faced with that uncertainty and no federal proceeding, the majority gave the state law a presumption of constitutionality, resolved doubts for the claimant, and concluded the Constitution did not bar the widow’s recovery.

Real world impact

The decision means some workers who do part of their jobs on navigable waters can obtain state compensation when no federal finding exists, and it reduces the chance that an otherwise eligible claimant will be denied state benefits in a close case. Employers and insurers, however, still face uncertainty about whether state or federal rules apply in particular situations.

Dissents or concurrances

Justice Frankfurter joined the result while urging caution and calling for a legislative solution. Chief Justice Stone warned that the ruling creates overlapping coverage with the federal law and would prefer a clearer congressional fix.