## Facts

- Congress amended the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA) in 1972 to reduce coverage anomalies caused by a strict water’s-edge rule and to address modern cargo-handling, including containerization.
- The amendments expanded covered “navigable waters” to include adjoining piers, wharves, terminals, and similar areas customarily used for loading/unloading vessels, and required both a covered location (situs) and “maritime employment” (status).
- Blundo worked as a “checker” on a pier, checking and marking cargo unloaded from a vessel or from containers removed from a vessel.
- Blundo was injured when he slipped on ice while marking cargo that had been stripped from a container on the pier.
- Caputo was a member of a stevedoring gang but was temporarily hired by Northeast as a terminal laborer performing tasks involving loading and unloading containers and moving cargo within the terminal area.
- Caputo was injured on the pier while rolling a dolly with ship’s cargo into a consignee’s truck as part of the transfer from vessel-delivered cargo to land transportation.
- Administrative proceedings awarded LHWCA benefits to both claimants; the Benefits Review Board and the Second Circuit affirmed.

## Issues

1. Whether Blundo and Caputo satisfied the LHWCA “status” requirement as “employees” engaged in “maritime employment” under 33 U.S.C. § 902(3).
2. Whether their injuries occurred on a covered “situs” under 33 U.S.C. § 903(a), including an adjoining pier or terminal customarily used for vessel loading or unloading.
3. Whether coverage is limited by a cargo “point of rest” concept that would end maritime coverage once cargo is placed in storage or into a truck.

## Decision

- The Supreme Court affirmed the judgments upholding LHWCA benefits for both claimants.
- Both Blundo and Caputo met the status requirement because their work was part of longshoring operations or closely related cargo-transfer functions within the loading/unloading process.
- Both injuries occurred on a covered situs because the pier/terminal area adjoined navigable waters and was customarily used for loading and unloading vessels.
- The Court rejected the employers’ “point of rest” theory as inconsistent with the statutory text and Congress’s purpose in the 1972 amendments.

## Legal Principles

- Post-1972 LHWCA coverage generally requires both: (1) injury on a covered situs (adjoining pier/terminal or similar area used for vessel loading/unloading) and (2) worker status as an “employee” engaged in “maritime employment.”
- “Maritime employment” under § 902(3) is interpreted with an occupational and functional focus; work that is an integral part of vessel loading or unloading (including container-related tasks) can satisfy status even when performed on land within the terminal.
- A worker who spends at least some time in indisputably longshoring operations may remain covered when injured while performing other closely related cargo-handling tasks within the terminal.
- The situs requirement can encompass an entire adjoining terminal facility customarily used for loading/unloading, not merely the vessel or the water-adjacent edge of a pier.
- LHWCA coverage does not depend on identifying a cargo “point of rest”; statutory coverage does not turn on whether cargo has reached a particular step in the ship-to-land transportation chain.

## Conclusion

The Court held that the 1972 LHWCA amendments extend coverage to waterfront terminal workers performing integral cargo-handling functions on adjoining terminal areas, and it declined to limit coverage by a “point of rest” boundary in the movement of cargo from ship to land transportation.


Northeast Marine Terminal Co. v. Caputo, 432 U.S. 249 (1977)