Lewis v. Modular Quarters

Background

An injured shipyard worker who was employed by a subcontractor was hurt while setting up sandblasting equipment. His employer had been hired to work at a shipyard owned by a larger company. The worker received benefits under the federal Longshore and Harbor Workers’ Compensation Act (LHWCA) and then sued the shipyard owner in Louisiana state court for his injuries. The trial court and the Louisiana Court of Appeal held that a state-law rule protecting “statutory employers” barred the worker’s tort lawsuit. The state court said the federal law did not show Congress meant to eliminate those state-law immunities. Louisiana’s highest court declined discretionary review.

Reasoning

The key question was whether the federal LHWCA prevents states from applying their own “statutory employer” immunity to bar third-party tort suits by workers who get federal benefits. The Louisiana Court of Appeal concluded that the LHWCA’s language and history do not show Congress intended to remove state defenses to state-law claims, so state immunity applies and blocks the suit. The dissenting Justice here emphasized that federal appellate decisions are split on this question, arguing the Supreme Court should resolve the conflict among circuits.

Real world impact

Because the Supreme Court declined to take the case, the Louisiana judgment that the worker’s state-law tort claim is barred remains in place. That leaves injured maritime workers, their employers, and contractors uncertain about when state immunity will prevent lawsuits. The split among appellate courts means similar cases in other states may reach different results until a higher court settles the issue.

Dissents or concurrances

Justice White, joined by Justice Blackmun, dissented from the denial of review and would have granted review to resolve the circuit split and clarify whether the LHWCA preempts state immunity rules.