Sun Ship, Inc. v. Pennsylvania, 447 U.S. 715 (1980)

Sun Ship, Inc. v. Pennsylvania

No. 79-343

Argued April 14, 1980
Decided June 23, 1980
447 U.S. 715

APPEAL FROM THE COMMONWEALTH COURT OF PENNSYLVANIA

Syllabus

Held: A State may apply its workers’ compensation scheme to land-based injuries that fall within the coverage of the Longshoremen’s and Harbor Workers’ Compensation Act (Act), as amended in 1972. Pp. 717-726.

(a) Under the law governing jurisdiction over marine-related injuries before 1972, nonlocal maritime injuries fell under the Act, "maritime but local" injuries "upon the navigable waters of the United States," 33 U.S.C. § 903(a), could be compensated either under the Act or under state law, and injuries suffered beyond navigable waters -- albeit within the range of federal admiralty jurisdiction -- were remediable only under state law. Cf. Davis v. Department of Labor, 317 U.S. 249; Calbeck v. Travelers Insurance Co., 370 U.S. 114; Nacirema Operating Co. v. Johnson, 396 U.S. 212. Pp. 717-719.

(b) The extension of federal jurisdiction landward beyond the shoreline of the navigable waters of the United States under the 1972 amendments of the Act supplements, rather than supplants, state compensation law. The language of the 1972 amendments cannot fairly be understood as preempting state workers’ remedies from the field of the Act, and thereby resurrecting the jurisdictional monstrosity that existed before the clarifying opinions in Davis, supra, and Calbeck, supra. Nor does the legislative history suggest a congressional decision to exclude state laws from the terrain newly occupied by the post-1972 Act. Pp. 719-722.

(c) The disparities which Congress had in view in amending the Act lay primarily in the paucity of relief under state compensation laws, and concurrent jurisdiction for state and federal compensation laws is not inconsistent with the amendments’ policy of raising awards to a federal minimum. Even though, if state remedial schemes are more generous than federal law, concurrent jurisdiction could result in more favorable awards for workers’ injuries than under an exclusively federal compensation system, there is no evidence that Congress was concerned about a disparity between adequate federal benefits and superior state benefits, the quid pro quo to employers for the 1972 landward extension of the Act being simply the abolition of the longshoremen’s unseaworthiness remedy. Nor does the bare fact that the federal and state compensation systems are different give rise to a conflict that, from the employer’s standpoint, necessitates exclusivity for each system within a separate sphere, since, even were the Act exclusive within its field, many employers would be compelled to abide by state-imposed responsibilities lest a claim fall beyond the Act’s scope. Pp. 723-726.

41 Pa.Commw. 302, 398 A.2d 1111, affirmed.

BRENNAN, J., delivered the opinion for a unanimous Court.