Calbeck v. Travelers Insurance Co.

Background

A deputy federal official approved compensation awards to two welders hurt while working on unfinished drilling barges that had been launched and were floating. The employers and insurers had argued that state workers’ compensation laws could cover injuries from new ship construction, so federal benefits under the Longshoremen’s Act should not apply. Lower courts split on that question, and the appeals court set aside the federal awards.

Reasoning

The central question was whether the Longshoremen’s and Harbor Workers’ Compensation Act was meant to cover all injuries occurring on navigable waters, even when a state law might also constitutionally provide compensation. The majority looked to the law’s history and earlier Supreme Court decisions and concluded Congress intended a uniform federal remedy to avoid gaps and uncertainty left by prior rulings. The Court reversed the appeals court, held the federal Act reaches injuries on navigable waters (including dry docks), and said acceptance of state payments does not bar a federal claim; such payments are simply credited against the federal award.

Real world impact

Shipyard workers injured while working on vessels afloat can seek federal compensation under this Act, reducing the risk that injuries will go uncompensated because of confusing state-federal lines. Employers and insurers face clearer federal liability for maritime work. The decision does not disturb statutory exclusions for seamen, masters, or certain federal or state employees.

Dissents or concurrances

Justice Stewart, joined by Justice Harlan, dissented, arguing the statute’s plain words limit federal recovery to cases where state law could not validly provide compensation and that Congress meant federal law only to fill gaps left by prior Court decisions.