Workers’ Compensation · Primary-source case analysis

Pfeiffer: Land-Based Cargo Handling Can Be Maritime Employment Under the Longshore Act

By Aneeta Mishra and Timothy Chan

Published August 22, 2026

P.C. Pfeiffer Co. v. Ford addressed workers who moved cotton from a pier warehouse toward rail shipment and unloaded military vehicles from railcars for eventual loading aboard vessels.

Maritime status is occupational

The inquiry focuses on the nature of the employee’s assigned work, not whether the worker happened to stand on water or crossed a geographic line at the moment of injury.

Intermediate cargo steps were integral to longshoring

Moving goods between a ship and the first landward mode of transportation remains part of the loading or unloading process despite division among employers and modern equipment.

The situs requirement remains separate

A maritime occupation does not alone establish coverage; the injury must also occur on navigable waters or an adjoining area satisfying the statutory location test.

The outer boundary is fact dependent

Purely clerical, manufacturing, or remote transportation work may fall outside coverage. Facility function and regular duties require careful proof.

Key takeaways

• Describe the worker’s regular cargo-handling tasks.
• Map the entire ship-to-land movement of the goods.
• Establish statutory situs independently.
• Check current circuit rules for the loading and unloading boundary.