Director, Office of Workers' Compensation Programs v. Perini North River Associates
Headline: Marine construction worker injured on navigable waters is covered by federal maritime compensation law; Court reverses lower court and allows LHWCA benefits for workers performing duties on navigable waters.
Holding:
- Makes it easier for marine construction workers injured on navigable waters to obtain federal LHWCA benefits.
- Reverses lower-court rulings that denied federal compensation for workers hurt on navigable waters.
- Leaves shoreside coverage subject to the Act’s status test; land-based claims still need status showing.
Summary
Background
A construction company hired workers to set large caissons and build a sewage plant foundation that extended over the Hudson River. Raymond Churchill, a marine construction worker, was directing unloading operations from a cargo barge when a line snapped and injured him. He claimed benefits under the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA). An administrative judge, the Benefits Review Board, and the Second Circuit denied coverage, finding his work lacked a relationship to navigation or commerce.
Reasoning
The Court addressed whether a worker injured while performing his job on actual navigable waters still meets the Act’s new 1972 “maritime employment” status requirement. The Justices reviewed earlier cases and the 1972 Amendments’ history. They found Congress expanded the geographic reach of coverage landward but did not intend to strip away protection that existed for workers who, before 1972, were injured on navigable waters. The status language was meant mainly to limit the new landward coverage, not to exclude workers who work and are injured on the water itself. Relying on precedent and the legislative reports, the Court concluded Churchill satisfied the status requirement and is covered by the amended LHWCA.
Real world impact
The decision restores federal compensation access for people who do their jobs on navigable waters and who would have been covered before 1972. It requires employers and insurers to treat such water-based injuries as potentially covered by the LHWCA. The ruling does not settle every situation — it does not decide coverage for workers only transiently or fortuitously on the water, and land-based claims remain governed by the Act’s status test.
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