Director, Office of Workers' Compensation Programs v. Rasmussen
Headline: Longshore and Defense Base Act death benefits are not limited by new disability caps, the Court held, allowing survivors to collect higher weekly payouts and increasing costs for employers and insurers.
Holding: The Court held that survivors’ death benefits under the Defense Base Act are not subject to the disability maximums in §6(b)(1), allowing beneficiaries to receive death payments without those caps.
- Allows survivors to receive death benefits not capped by disability limits
- May increase payouts employers and insurers must fund
- Resolves conflicting appeals-court rulings about benefit limits
Summary
Background
William Rasmussen was a hydrologist working for a contractor under the Defense Base Act in South Vietnam when he was killed by a land mine. His widow and son sought death benefits equal to two-thirds of his average weekly wages. The employer, its insurer, and the federal benefits director argued that a 1972 change to the law that set new caps on disability payments also limited death benefits. The dispute went through an administrative judge, the Benefits Review Board, and the Ninth Circuit, which ruled for Rasmussen’s survivors.
Reasoning
The central question was whether Congress meant the 1972 disability payment caps to apply to survivor death benefits. The Court looked to the statute’s text and the legislative history and found that Congress deliberately removed fixed dollar caps from the death-benefit provision and tied minimums to the national average weekly wage. The Court explained that the provision petitioners relied on simply referenced the Secretary’s yearly wage determination, not the disability cap formula. Because the statute and committee reports show Congress intended no maximum in the death-benefit section, the Court affirmed the lower court’s judgment.
Real world impact
Survivors covered by the Act can receive death payments without being automatically limited by the disability maximums created in 1972, which may raise payouts in some cases. The decision affects contractors, insurers, and families of deceased workers covered by the Defense Base Act and resolves conflicting appeals-court rulings on the issue.
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