Sun Ship, Inc. v. Pennsylvania
Headline: Court upholds state workers’ compensation for land-based injuries covered by the federal Longshoremen’s Act, letting shipyard workers seek state benefits alongside federal claims and preserving concurrent remedies.
Holding: The Court held that a State may apply its workers’ compensation law to land-based injuries that fall within the coverage of the 1972-amended Longshoremen’s and Harbor Workers’ Compensation Act, allowing concurrent state and federal remedies.
- Lets injured shipyard workers pursue state compensation even when federal law also applies.
- Employers may face both state and federal compensation claims.
- Reduces the risk that workers must guess which forum will provide benefits.
Summary
Background
Five shipyard employees who worked for a shipbuilding and repair company on the Delaware River in Pennsylvania were hurt while doing ship repair or construction after Congress amended the federal Longshoremen’s and Harbor Workers’ Compensation Act in 1972. Although the federal law could apply, each worker filed for benefits under Pennsylvania’s workers’ compensation law. State tribunals awarded benefits, and those decisions were affirmed by Pennsylvania courts before the question reached the Supreme Court.
Reasoning
The Court reviewed a long line of precedent about when federal maritime compensation rules displace state laws. Earlier cases had created a confusing “twilight zone” where workers could be covered by either federal or state systems. The 1972 amendments extended federal coverage onto shore but did not clearly erase state remedies. The Court concluded the new language and legislative history do not show an intent to bar state compensation; instead, the amendments supplement federal law. Allowing state and federal remedies to operate together avoids forcing workers into risky choices between two exclusive systems and furthers Congress’ remedial purpose to help injured maritime laborers.
Real world impact
As a result, injured longshore and shipyard workers hurt on land may pursue state compensation even when the Longshoremen’s Act also applies. Employers remain subject to both sets of rules, with crediting rules to prevent double recovery. The ruling affirms that the 1972 federal expansion did not eliminate state workers’ remedies and preserves concurrent avenues for benefits.
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