Chesapeake & Ohio Railway Co. v. Schwalb

Background

Three railroad employees were hurt while working at coal-loading terminals where trains were unloaded into ships. Two were laborers who cleaned spilled coal from dumper rollers and conveyor belts; one was a pier machinist who repaired a retarder on a dumper. Each worker sued the railroad under the Federal Employers’ Liability Act (a negligence suit). Virginia’s highest court said the federal longshore compensation law did not apply, so the negligence cases could go forward.

Reasoning

The Supreme Court examined whether these workers were engaged in "maritime employment" under the Longshore and Harbor Workers’ Compensation Act (LHWCA). The Court explained that the Act covers land-based workers on the loading site who perform tasks that are integral or essential to loading or unloading a vessel. Repairing or cleaning essential loading equipment keeps the loading process running, so those tasks fall within the Act. Because the LHWCA provides the exclusive remedy for covered workers, the Court reversed the Virginia rulings and held that these employees must proceed under the Act rather than with negligence suits.

Real world impact

The decision means maintenance, repair, and cleaning personnel whose work is essential to ship loading are generally covered by the federal no-fault compensation system. Injured workers in similar settings will normally seek benefits under the LHWCA instead of suing their employer for negligence. The ruling resolves a conflict between courts and sets a national rule for coverage of such terminal workers.

Dissents or concurrances

Two concurring opinions emphasize that the ruling preserves the idea of “amphibious” workers and that coverage can be continuous even when a worker sometimes does other tasks.