Pillsbury v. United Engineering Co.

Background

These four consolidated cases involve injured maritime employees who sought benefits under the Longshoremen’s and Harbor Workers’ Compensation Act. Each worker was hurt on the job and filed a claim eighteen to twenty-four months after the injury. A Deputy Commissioner had allowed the claims as timely because each claim was filed within one year after the workers became disabled. The District Court set aside those awards, and the Court of Appeals held the claims barred because they were not filed within one year after the injury date.

Reasoning

The Court addressed whether the statute’s word 'injury' means the initial event of harm or the later start of compensable 'disability.' Looking at the Act’s language and definitions, the Court concluded Congress used 'injury' and 'disability' as distinct terms and meant the one-year limit to run from the injury date. The Court noted the Act defines both words and said it could not rewrite the statute to delay the filing period until disability began, so it affirmed the lower courts’ judgments.

Real world impact

As a result, injured maritime workers who wait more than one year after the injury to file may lose the right to compensation even if their disabling loss of earning power appears later. The decision resolves a split among courts about when the one-year period starts. The ruling leaves Congress, not the courts, as the avenue for changing the filing deadline if a different rule is desired.

Dissents or concurrances

Three Justices disagreed, arguing the one-year period should run from the date a compensable disability first arises, which would have allowed these claims because the Deputy Commissioners found the claims were filed within one year after disability began. They believed measuring from injury frustrates the Act’s remedial purpose.