Goodyear Atomic Corp. v. Miller

1988-05-23

Headline: State workers’ compensation extra-award upheld, allowing Ohio to require additional payments from a private contractor at a federally owned nuclear plant when state safety rules are violated.

Holding: The Court held that Congress, through 40 U.S.C. §290, authorized states to apply Ohio’s supplemental workers’ compensation award to employees of a private contractor at a federally owned nuclear facility.

Real World Impact:

Enables injured workers at federal facilities to seek Ohio supplemental awards for safety-rule violations.
Makes private contractors on federal property financially responsible for state safety penalty awards.
Reinforces that a 1936 federal law allows state compensation rules on federal premises.

Topics: workers' compensation, federal facilities, nuclear plant safety, state vs federal power

Summary

Background

A maintenance mechanic employed by a private contractor at the Portsmouth Gaseous Diffusion Plant fell from a scaffold and fractured his ankle. He received about $9,000 in ordinary workers’ compensation and then applied for an additional state award, saying the employer violated an Ohio scaffold safety rule. Ohio’s Industrial Commission denied the supplemental award, but Ohio courts ordered the Commission to consider it and the Ohio Supreme Court upheld the law’s application to the federal plant.

Reasoning

The central question was whether a 1936 federal law, 40 U.S.C. §290, lets States apply their workers’ compensation laws — including Ohio’s extra award for violation of a specific safety rule — to employees working on federal property. The Court said federal facilities are generally immune from state regulation unless Congress clearly authorizes it. The Court concluded that §290’s plain language and the historical practice of many States made clear Congress intended state compensation schemes like Ohio’s to apply “to the same extent,” so the supplemental award is authorized and not barred by federal law.

Real world impact

The decision means injured workers at federal facilities can seek the same state supplemental awards they would get at private worksites, and contractors operating federal plants may face higher premiums or extra payments when they violate state safety rules. The ruling affects nuclear production facilities and could influence how other States’ safety-linked compensation laws apply on federal property. The Supreme Court resolved the federal question, though individual claims must still be decided by the state commission.

Dissents or concurrances

Justice White, joined by Justice O’Connor, dissented. He argued Congress did not clearly authorize imposing these detailed state penalty rules on federal instrumentalities and warned the extra payments operate like coercive regulation over federal facilities.