Workers’ Compensation · Primary-source case analysis

Caputo: Congress Expanded Longshore Coverage for Modern Shoreside Cargo Work

By Aneeta Mishra and Timothy Chan

Published August 23, 2026 · Updated October 17, 2026

Decision: Northeast Marine Terminal Co. v. Caputo, 432 U.S. 249 (1977).

Northeast Marine Terminal Co. v. Caputo, decided June 17, 1977, addressed a checker unpacking imported container cargo and a longshore worker loading cargo into a delivery truck. Its practical question was whether containerization and changing daily assignments could cut workers out of federal coverage even though they performed traditional cargo functions.

The amendments added status and situs tests

The statute separately asks what work the employee does (maritime status) and where the injury happens (covered situs). Being at a waterfront terminal alone is not enough, and maritime duties do not eliminate the location requirement. Caputo, 432 U.S. at 252, 267.

Congress responded to the shoreline coverage gap

Containerization moved loading and unloading functions inland, and Congress sought uniform protection rather than benefits that switched on and off as workers crossed the water’s edge.

Cargo handling remained maritime employment

Checker Biundo marked cargo being removed from a sealed container that had arrived overland from another pier. The Court held that moving the unopened container had not completed unloading; checking its contents remained part of that process. Caputo also qualified because his regular and assignable duties included indisputable longshore work. The Court did not adopt a rule covering everyone who ever handled cargo at a terminal. Caputo, 432 U.S. at 270–274.

The functional facts control

Job title alone is insufficient. The employee’s regular duties, the facility’s use, proximity, and relationship to loading, unloading, repair, or shipbuilding must be developed.

Key takeaways

• Map the injury location and facility boundaries.
• Describe the employee’s regular cargo or vessel functions.
• Apply both status and situs independently.
• Check current circuit law on adjoining-area limits.