Workers’ Compensation · Primary-source case analysis
Davis: A Maritime Worker Could Recover Under State Law in the Jurisdictional Twilight Zone
Primary source: Read the filed decision PDF.
Decision: Supreme Court of the United States, No. 86, decided December 14, 1942. Document: Published United States Reports opinion.
Davis v. Department of Labor and Industries involved a worker who drowned while cutting dismantled bridge steel aboard a barge on a navigable river.
The work mixed land and maritime features
The crew cut bridge steel, lowered it to a barge, and prepared it for transport.
The state court rejected compensation
It concluded federal maritime exclusivity barred the widow’s state claim.
Borderline coverage was fact intensive
The Supreme Court described a twilight zone in which presumptions favor the applicable compensation law and agency conclusions.
The judgment was reversed
With no conflicting federal proceeding, the Constitution did not prevent Washington from granting benefits.
Key takeaways
- Develop situs, status, task, and vessel facts.
- Check both state and federal compensation statutes.
- Identify any existing federal administrative action.
- Do not assume navigable water automatically defeats state coverage.
Discuss the procedural record
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