P. C. Pfeiffer Co., Inc. v. Ford
Annotate this Case
444 U.S. 69 (1979)
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U.S. Supreme Court
P. C. Pfeiffer Co., Inc. v. Ford, 444 U.S. 69 (1979)
P. C. Pfeiffer Co., Inc. v. Ford
Argued March 20, 1979
Reargued October 1, 1979
Decided November 27, 1979
444 U.S. 69
Section 2(3) of the Longshoremen's and Harbor Workers' Compensation Act, as amended in 1972, defines an employee as "any person engaged in maritime employment, including any longshoreman or other person engaged in longshoring operations. . . ." The question in this case is whether two workers were engaged in "maritime employment," as defined by § 2(3), when they sustained injuries for which they sought compensation. Respondent Ford was injured on a public dock in the Port of Beaumont, Tex., while employed by petitioner P. C. Pfeiffer Co. and while fastening onto railroad flatcars military vehicles that had been delivered to the port by ship, stored, and then loaded the day before the accident onto the flatcars. Respondent Bryant, while working as a cotton header for petitioner Ayers Steamship Co. in the Port of Galveston, Tex., was injured while unloading a bale of cotton from a dray wagon into a pier warehouse. Cotton arriving at the port from inland shippers enters storage in cotton compress-warehouses, then goes by dray wagon to pier warehouses, and later is moved by longshoremen from the warehouses onto ships. Both Ford's and Bryant's claims for coverage were denied by Administrative Law Judges applying the "point of rest" doctrine whereby maritime employment would include only the portion of the unloading process that takes place before the stevedoring gang places cargo onto the dock and the portion of the loading process that takes place to the seaside of the last point of rest on the dock. The Benefits Review Board reversed both decisions, and the Court of Appeals affirmed. On remand for reconsideration in light of this Court's decision in Northeast Marine Terminal Co. v. Caputo, 432 U. S. 249, which rejected the "point of rest" theory, the Court of Appeals reaffirmed its earlier opinion.
Held: Ford and Bryant were engaged in maritime employment at the time of their injuries, because they were engaged in intermediate steps of moving cargo between ship and land transportation. Pp. 444 U. S. 77-84.
(a) Petitioners' position that the Act covers only workers who are working or who may be assigned to work over the water itself is inconsistent with the language and structure of the Act, which contains distinct
situs and status requirements. Section 3(a) of the Act allows recovery for an injury suffered on navigable waters or certain adjoining areas landward of the water's edge, thus defining the broad geographic coverage of the Act, whereas § 2(3) defines the Acts occupational requirements, referring to the nature of a worker's activities. The legislative history also shows that Congress intended the term "maritime employment" in § 2(3) to refer to status, rather than situs. In adopting an occupational test that focuses on loading and unloading, Congress anticipated that some persons who work only on land would receive benefits under the Act. Cf. Northeast Marine Terminal Co. v. Caputo, supra. Pp. 444 U. S. 77-81.
(b) Ford and Bryant are the kind of land-based employees that Congress intended to encompass within the term "maritime employment." Both men engaged in the type of duties that longshoremen perform in transferring goods between ship and land transportation. Under § 2(3), workers doing tasks traditionally performed by longshoremen are within the purview of the Act. The crucial factor is the nature of the activity to which a worker may be assigned. Persons moving cargo directly from ship to land transportation are engaged in maritime employment, and a worker responsible for some portion of that activity is as much an integral part of the process of loading or unloading a ship as a person who participates in the entire process. Pp. 444 U. S. 81-84.
575 F.2d 79, affirmed. POWELL, J., delivered the opinion for a unanimous Court.