Peters v. Veasey

Background

A longshoreman named Veasey was injured on August 6, 1915, when he fell through a hatchway while unloading the steamer “Seria” at New Orleans. He sued under Louisiana’s Workmen’s Compensation Law after his employers, Henry and Eugene Peters, and an insurance policy issued by Aetna were involved. The state supreme court had upheld a judgment for Veasey applying the later 1917 federal change allowing claimants to use state compensation rights.

Reasoning

The Court examined whether the accident and the employment were maritime in nature. It found the work, the employment contract, and the injuries to be maritime, so the rights and liabilities belonged in admiralty (maritime) law. The Court reviewed the Judicial Code and a 1917 congressional amendment that added language about allowing claimants to use state workers’ compensation. The Justices held that the 1917 amendment did not indicate any intent to apply to events that happened before the amendment. Because the injury occurred in 1915, the state compensation law did not apply and the lower court erred in giving the 1917 change retroactive effect.

Real world impact

The Court reversed the state court’s judgment and sent the case back for further proceedings consistent with its opinion. In practical terms, the decision means that injuries to maritime workers that happened before the 1917 amendment remain governed by maritime law, not by the later state compensation rights, unless Congress clearly states otherwise.

Dissents or concurrances

Two Justices, Brandeis and Clarke, dissented. Their views were noted but the majority’s ruling controlled the outcome.