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

Northeast Marine Terminal Co. v. Caputo involved terminal workers injured while handling cargo in areas adjoining navigable waters after technology had shifted traditional longshore tasks shoreward.

The amendments added status and situs tests

Coverage depends on both maritime employment and injury within navigable waters or specified adjoining areas used for vessel-related activity.

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

Workers engaged in intermediate steps of moving cargo between ship and land transportation could satisfy maritime status even when not aboard a vessel at the moment of injury.

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.