Workers’ Compensation · Primary-source case analysis

Federal Sheet Metal: The Longshore Presumption Could Not Supply a Claim the Worker Did Not Make

By Aneeta Mishra and Timothy Chan

Published August 19, 2026

U.S. Industries/Federal Sheet Metal, Inc. v. Director, OWCP involved a worker who alleged a specific lifting accident at work, which the factfinder found had not occurred, after he awoke the next morning with severe pain.

The pleaded accident was rejected on the evidence

The administrative law judge found that the asserted workplace lifting incident did not occur and denied the claim.

The court could not invent a different claim

The court of appeals treated the later onset of pain at home as an employment-bred injury, but that was not the claim the worker presented.

Section 20(a) attaches to a prima facie claim

The presumption assists with a claim that alleges the required work-connected injury; it does not eliminate the need to identify harm and working conditions that could have caused it.

Accurate alternative theories matter

A claimant should develop cumulative-trauma, aggravation, occupational-disease, or delayed-symptom theories in the administrative record when supported rather than relying on a disproved single event.

Key takeaways

• State each claimed injury mechanism and date accurately.
• Develop evidence of both harm and relevant working conditions.
• Amend or clarify the claim promptly when the medical theory changes.
• Do not use a statutory presumption as a substitute for a prima facie claim.