Lewis v. Modular Quarters

Background

A worker who was employed by a subcontractor at a shipyard was injured while setting up sandblasting equipment. The worker began receiving benefits under the federal Longshore and Harbor Workers’ Compensation Act (LHWCA) and then sued the contractor that hired his employer, saying the contractor was responsible for his injury. The trial court granted summary judgment for the contractor, and the Louisiana Court of Appeal affirmed. The Louisiana Supreme Court denied review.

Reasoning

The central question was whether the federal LHWCA prevents states from applying a state-law immunity for “statutory employers” that can block third-party tort suits by workers who already get LHWCA benefits. The Louisiana Court of Appeal concluded that Congress did not intend the LHWCA to negate state-law defenses to state tort claims, so the state statutory-employer immunity barred the worker’s suit. The dissenting federal judges and some other appeals courts have disagreed, creating conflicting outcomes in different regions.

Real world impact

Because the higher court declined to review the case, the lower-court ruling stands, which means this injured worker cannot sue the contractor in state court. The decision leaves similar cases to be decided differently in other appeals courts and keeps the legal conflict unresolved for maritime workers, contractors, and employers. This is not a final merits decision by the high court and could change if the issue is taken up later.

Dissents or concurrances

Justice White, joined by Justice Blackmun, dissented from the denial of review and said the justices should hear the case to resolve the circuit split about the LHWCA’s pre-emptive effect.