Workers’ Compensation · Primary-source case analysis

Pfeifer: Longshore Compensation Did Not Bar Vessel Negligence, and Future Earnings Required a Deliberate Discount Rate

By Aneeta Mishra and Timothy Chan

Published September 9, 2026

Jones & Laughlin Steel Corp. v. Pfeifer arose after a barge-loading worker received Longshore Act benefits and also recovered damages for the vessel owner's negligence.

The worker was permanently limited after a barge fall

Pfeifer slipped on snow and ice while carrying a pump on his employer's coal barge. The injury prevented a return to his former job and limited him to light work.

Owner-employer status did not eliminate vessel liability

Although the company paid compensation as employer, section 5(b) allowed a negligence action against the vessel in the circumstances presented. The statutory text and history defeated a blanket immunity theory.

Future earnings required present-value analysis

The trial court assumed future inflation and interest would offset and applied a state-law rule without making an independent discount-rate choice. The Supreme Court held that federal maritime law controlled and discussed methods for estimating future earnings and present value.

The damages judgment was vacated

The Court did not impose one exclusive forecasting method, but required a deliberate choice consistent with the earnings assumptions rather than automatic reliance on state law. It vacated and remanded.

Key takeaways

• Separate compensation exclusivity from any statutory vessel-negligence claim.
• Identify which entity acted as employer, vessel owner, and stevedore.
• State every assumption used for worklife, wage growth, inflation, taxes, and discounting.
• Use a damages method consistent with the governing federal or state substantive law.