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 · Updated October 29, 2026

Decision: U.S. Indus./Fed. Sheet Metal, Inc. v. Director, OWCP, 455 U.S. 608 (1982).

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

A presumption helps with a claim the worker has actually made; it does not require the judge to invent every possible alternative theory. The Court expressly left the full scope of the presumption unresolved. It held that the pleaded claim and work connection could not be supplied by pointing only to symptoms that appeared at home. Federal Sheet Metal, 455 U.S. at 612–616.

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.

Justice Brennan, joined by Justice Marshall, dissented. He would have upheld a remand for the agency to consider whether Riley’s neck condition was work-related even if the alleged lifting incident had not happened. He read the statutory presumption and the informal claims process as requiring the employer to rebut that connection, rather than treating the rejected incident as the end of the inquiry. He also pointed to procedures allowing issues to be clarified or a hearing reopened. The majority’s narrower view of the claim presented controlled the result. Federal Sheet Metal, 455 U.S. at 617–623 (Brennan, J., dissenting).

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.