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 · Updated October 29, 2026

Decision: Morrison-Knudsen Constr. Co. v. Director, OWCP, 461 U.S. 624 (1983).

Morrison-Knudsen Construction Co. v. Director, OWCP, decided May 24, 1983, addressed employer contributions to union trust funds when calculating survivors’ death benefits. James Hilyer was fatally injured on the D.C. Metrorail project. The District of Columbia compensation law incorporated the federal Longshore Act; this was not a California wage-calculation case. Morrison-Knudsen, 461 U.S. at 626–629.

The statute defined wages through monetary compensation

The version of the statute before the Court included money compensation, specified benefits such as board and lodging, similar advantages and gratuities. The question was whether trust-fund contributions were similar to board or lodging. Those benefits had a present market value readily convertible to cash; the trust interests did not. Morrison-Knudsen, 461 U.S. at 629–631.

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.

Justice Marshall dissented and would have included the employer’s trust-fund contributions. He reasoned that the Act sought to replace lost earning power, and employees who bargained for benefits instead of cash had earned that part of their compensation too. The agreed contribution rate provided a reasonable way to value it even if the eventual individual benefit was uncertain. He disputed relying on congressional silence and administrative consistency, noting that the agency had changed its position in this very case. The majority instead found the contingent trust interests different from the immediately valued advantages covered by the historical wage definition. Morrison-Knudsen, 461 U.S. at 638–647 (Marshall, J., dissenting).

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.