Patterson v. United States

Background

Several civilian employees were hurt while working aboard vessels operated by the United States in the merchant service; one worker died and an administrator sued on his behalf. Each of the claimants filed maritime lawsuits against the Government under the Suits in Admiralty Act, and the Court of Appeals for the Second Circuit dismissed those suits as barred by the federal workers’ compensation law. The Supreme Court took the case to resolve a conflict with another appellate court.

Reasoning

The key question was whether these injured civilian seamen could bring separate maritime damage suits against the United States or must accept the Federal Employees’ Compensation Act as their only remedy. The Court relied on its earlier Johansen decision, stating the same reasons apply when the government vessel is in merchant service and that having two different systems of relief would be wrong. The Justices declined the claimants’ invitation to overrule Johansen and affirmed dismissal of the lawsuits, noting Congress could change the law if it wished.

Real world impact

The ruling means injured civilian seamen who work on government-operated merchant vessels generally cannot obtain damage awards by suing the United States in maritime court. Instead, they are directed to seek benefits under the Federal Employees’ Compensation Act. The opinion also cites later Congressional action showing lawmakers have considered which remedies to provide, and it leaves any expansion of remedies to Congress.

Dissents or concurrances

Justices Black and Douglas dissented from the decision to affirm and from the refusal to reopen the earlier rule, indicating disagreement though the opinion does not detail their reasoning.