McMahon v. United States
Headline: Time limit for seamen’s injury claims against the United States starts on the injury date, not when the government rejects the claim, so delayed lawsuits can be barred by the two-year rule.
Holding: The Court held that the two-year deadline to sue the United States for a seaman’s injury starts on the date of the injury, not when an administrative claim is disallowed, and affirmed the lower court.
- Makes seamen’s injury claims against the U.S. time-barred if filed more than two years after injury.
- Prevents claimants from delaying filing to extend the two-year deadline against the Government.
- Leaves open whether a sixty-day administrative waiting period pauses the deadline.
Summary
Background
A seaman sued the United States after suffering injuries aboard a government-owned ship, claiming negligence, unseaworthiness, and maintenance and cure. The injuries occurred in November and December 1945, but his lawsuit was not filed until January 22, 1948. A law gives seamen on government vessels the same rights as those on private ships and allows suits if a claim is administratively disallowed.
Reasoning
The Court addressed whether the two-year time limit to sue starts at the injury date or when an administrative claim is disallowed. The majority said the limitation period runs from the date of the injury. The Court reasoned that the limitation language predates the authorization to sue on administratively disallowed claims and was understood to run from the event creating the claim. The opinion also noted that waivers of the Government’s immunity are construed narrowly and that allowing claimants to delay filing would let them postpone the start of the deadline indefinitely.
Real world impact
The ruling means seamen who are injured on government vessels must be mindful of the two-year filing deadline measured from the injury date, not from administrative rejection. The opinion noted a regulation that treats claims not denied in writing within sixty days as presumed disallowed, but the Court declined to decide whether that sixty-day period tolls the deadline because the record did not show when the claim was filed or denied.
Dissents or concurrances
Justices Black and Douglas disagreed and would have held that the time limit begins only when the claim is administratively disallowed, following a Ninth Circuit decision; one Justice did not participate.
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