Workers’ Compensation · Primary-source case analysis

Morrison-Knudsen: Employer Trust-Fund Contributions Were Not Longshore Wages

By Aneeta Mishra and Timothy Chan

Published August 24, 2026

Morrison-Knudsen Construction Co. v. Director, OWCP addressed whether employer-paid fringe-benefit contributions belonged in an injured worker’s average weekly wage.

The statute defined wages through monetary compensation

The Court focused on pay delivered to the employee and the statutory treatment of advantages that could be measured in money and were included for tax-withholding purposes.

The contributions went to independent trust funds

The employer paid negotiated amounts to multiemployer plans rather than directly to the worker, and the worker did not receive a present dollar-for-dollar entitlement.

Benefit value was contingent and difficult to individualize

Eligibility and eventual plan benefits depended on fund rules and events beyond the particular contribution, distinguishing the payments from immediate remuneration.

Later statutory text controls current claims

Congress amended the Longshore Act’s wage definition after the period involved. Current federal and state compensation calculations must use the law governing the claim.

Key takeaways

• Identify every component of remuneration.
• Trace whether payment goes to the worker or an independent plan.
• Apply the wage definition in force on the relevant date.
• Do not transfer the holding automatically to California benefit calculations.