## Facts

- Perini North River Associates performed marine construction for a sewage treatment plant extending over the Hudson River in New York.
- Raymond Churchill, a Perini employee, worked on the deck of a cargo barge used in the project.
- Churchill was injured while performing his job duties on the barge while it was on actual navigable waters.
- Churchill sought benefits under the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA), as amended in 1972.
- An administrative law judge and the Benefits Review Board denied the claim, concluding Churchill was not “engaged in maritime employment” under LHWCA § 2(3).
- The Second Circuit affirmed, applying a “significant relationship to navigation or commerce on navigable waters” test and finding Churchill’s work insufficiently maritime.
- The Director, Office of Workers’ Compensation Programs sought Supreme Court review; Churchill participated and argued he was entitled to coverage.

## Issues

1. Whether a justiciable case or controversy existed, including whether the Court could reach the merits when the Director sought review and the employee supported coverage.
2. Whether a worker injured in the course of employment on actual navigable waters is covered by the LHWCA after the 1972 amendments without separately satisfying a “maritime employment” status test under § 2(3).

## Decision

- The Supreme Court held the matter was justiciable because the injured employee, as a party before the Court, had a sufficient personal stake and urged consideration of the merits.
- The Court reversed the Second Circuit.
- The Court held that Churchill, a marine construction worker injured while working on actual navigable waters, was covered by the LHWCA.
- The case was remanded for further proceedings consistent with the Court’s interpretation of coverage.

## Legal Principles

- Pre-1972 LHWCA coverage extended to workers injured on actual navigable waters in the course of employment, without further inquiry into the specific maritime character of the work.
- The 1972 amendments expanded coverage landward and added a status requirement, but did not withdraw preexisting coverage for injuries occurring on actual navigable waters absent a clear statement from Congress.
- For injuries on actual navigable waters, an employee who would have been covered before 1972 remains covered after 1972 without having to prove an additional “significant relationship to navigation or commerce on navigable waters.”
- The “maritime employment” status requirement primarily operates to limit the newly extended landward situs coverage, not to restrict coverage for on-water injuries.
- The LHWCA is remedial and is construed in favor of coverage where consistent with the statute and Congress’s evident purpose.

## Conclusion

The Supreme Court ruled that the LHWCA continues to cover workers injured on actual navigable waters as it did before 1972, and that courts may not deny such coverage by imposing an extra status inquiry requiring a distinct relationship to navigation or maritime commerce.


Dir., Off. of Workers’ Comp. Programs v. Perini N. River Assocs., 459 U.S. 297 (1983)