Intercounty Constraction Corp. v. Walter
The Court ruled that a one-year deadline in the federal workers' compensation law for reviewing awards applies only to changing decisions already made by the deputy commissioner, not to claims that were filed on time but never ruled on at all.
This meant a disabled construction worker's decade-old, still-pending disability claim could still be decided on the merits, even though more than a year had passed since his insurer's last voluntary payment.
“Whatever the merits of a fixed period for resolution of pending compensation claims not previously the subject of an order, Congress did not in § 22 establish such a period.”
The Court's concluding explanation for why the claim was not time-barred.
How it got here: A federal trial court ruled the claim was time-barred; the D.C. Circuit reversed, and the Supreme Court took the case due to a circuit conflict.
The Case in Depth
What happened
A construction worker was injured in 1960 and promptly filed a claim for total permanent disability under a federal workers' compensation law. His employer's insurer began paying him weekly benefits without waiting for a formal ruling, later reduced the payments, and eventually stopped paying altogether in 1968 after reaching a payment cap. The worker's original claim, however, was never formally decided by the agency for a decade.
The question before the Court
If a worker files an injury claim on time but the government official never rules on it, can the employer's insurer later argue the claim expired just because a year passed since it stopped paying benefits?
Why it matters
Insurance carriers and employers who make voluntary compensation payments without ever getting a formal ruling cannot use the passage of time to wipe out a worker's still-pending claim. Workers whose claims linger for years without action by the agency retain the right to have those claims decided, protecting them from losing benefits due to bureaucratic delay.
What changes now
The ruling affirms the lower appeals court's decision, meaning the disabled worker's award of permanent total disability compensation stands. This is a final merits decision resolving the legal question of how the deadline provision applies; the case does not appear to be remanded for further proceedings on this issue, since the underlying award was already entered by the deputy commissioner and upheld here.
What this does not decide
The Court did not decide whether Congress should adopt a fixed deadline for resolving compensation claims that have never been ruled on — it noted that whatever the merits of such a rule, Congress had not actually written one into the modification provision at issue.
Concurrences and dissents
How the Justices voted
Majority (1). Justice Rehnquist (author).
How the Court got there
The legal reasoning, step by step
- The Court examined whether a provision allowing a deputy commissioner to 'modify' compensation awards within one year of the last payment also created a separate deadline barring never-yet-decided claims, on top of the one-year filing deadline set by a different section of the law.
- Because the modification provision used ambiguous phrases like 'new order' and 'rejection of a claim' alongside language suggesting broader reach ('whether or not a compensation order has been issued'), the Court found the text alone did not resolve the question and turned to the law's legislative history.
- Tracing the provision from its 1927 origin through amendments in 1934 and 1938, the Court found that Congress consistently described the changes as broadening the agency's power to revisit awards it had already made, never as creating a new deadline for claims still awaiting a first decision.
- Congressional committee reports and a subsequent 1938 amendment addressing 'cases finally acted upon by the deputy commissioner' confirmed that the one-year modification deadline was understood by Congress to apply only to previously decided cases, not to claims still pending initial resolution.
- Applying this understanding, the Court concluded that the one-year modification deadline did not bar the worker's claim, because his claim had never been the subject of any prior order by the deputy commissioner.
Doctrinal impact
Cases affected by this decision
Reaffirms Banks v. Chicago Grain Trimmers (390 U.S. 459)
Relied on for the purpose behind the 1934 amendment broadening modification grounds.