Marshall v. Pletz

Background

A longshoreman was hurt while loading a ship. His employer’s insurer repeatedly discussed payment, offered money, and provided medical care. The worker refused early checks and later filed a compensation claim after the one-year period set by the law. A claims official denied the late claim and lower federal courts reached conflicting results about whether the insurer’s conduct prevented the one‑year rule from applying.

Reasoning

The central question was whether an insurer’s tender of money or the provision of medical care counts as “payment of compensation” and so extends the one‑year filing deadline. The Court said no. It explained that the statute defines “compensation” as money paid to the worker and treats medical care separately. A mere offer or tender of payment is not the same as actual payment, and supplying medical treatment does not qualify as money compensation that restarts the filing period. The Court reversed the lower courts’ rulings and sent the case back for further proceedings consistent with this interpretation.

Real world impact

The decision means injured maritime workers who do not accept actual money payments must still file claims within the statutory year, even if insurers negotiated or provided medical care. Employers and insurers cannot automatically toll the filing deadline simply by offering payment or giving medical aid. The ruling preserves strict time limits for bringing compensation claims under the Act.

Dissents or concurrances

A dissent argued the insurer’s continuous negotiations and promises to pay led the worker to delay filing, and that equity should prevent the insurer from using the one‑year deadline as a defense. This view highlights a dispute about fairness versus strict statutory timing.