Roberts v. Sea-Land Services, Inc.

Background

An injured longshore worker slipped on ice in 2002 and stopped working. His employer, a shipping company, paid benefits voluntarily for a time but later stopped. After a formal hearing in 2007, an administrative judge awarded benefits and applied the benefit cap based on the fiscal year when the worker first became disabled. The worker argued the cap should instead be based on the year the judge issued the award.

Reasoning

The Court examined whether “newly awarded compensation” means the year a worker becomes entitled to benefits or the year a formal order is issued. The phrase was ambiguous in isolation, so the Court read it in the context of the Longshore Act’s overall scheme. The Act commonly relies on voluntary employer payments and requires employers to calculate caps when payments begin. Interpreting the phrase to mean the date of disability gives an administrable rule, treats similar workers equally, and avoids incentives to delay or manipulate claims.

Real world impact

The Court held that the cap is fixed by the fiscal year in which a worker first becomes disabled and is entitled to benefits, regardless of when a formal order issues. That means injured maritime workers’ maximum weekly benefits are set at disability onset, and employers and claims examiners will use that date to calculate caps. The decision resolves the circuit split and makes the rule final for these types of claims.

Dissents or concurrances

Justice Ginsburg disagreed in part: she would treat a worker as “newly awarded” when the employer voluntarily begins paying or when an official order directs payment, arguing that approach better encourages prompt employer payments.