## Facts

- Two consolidated claims sought benefits under the Longshore and Harbor Workers’ Compensation Act (LHWCA), as amended in 1972.
- Diverson Ford worked for P.C. Pfeiffer Co. on a public dock at the Port of Beaumont, Texas.
- Ford was injured while fastening military vehicles—delivered by ship, stored, and then loaded onto railroad flatcars the day before—onto the railcars for inland transport.
- Willie Bryant worked for Ayers Steamship Co. as a cotton header at the Port of Galveston, Texas.
- Bryant was injured while unloading a bale of cotton from a dray wagon into a pier warehouse; the cotton later would be moved from the warehouse onto ships.
- Administrative law judges denied both claims using a “point of rest” view that limited coverage to only certain dockside segments of loading/unloading.
- The Benefits Review Board reversed, and the Fifth Circuit affirmed coverage; after remand following intervening Supreme Court precedent rejecting the “point of rest” approach, the Fifth Circuit reaffirmed.
- The Supreme Court granted certiorari and consolidated the cases.

## Issues

1. Whether Ford and Bryant were “engaged in maritime employment” under LHWCA § 2(3) when injured while performing land-based cargo-handling tasks in port facilities.
2. Whether “maritime employment” is an occupational (status) concept distinct from the Act’s geographic (situs) requirement, rather than limited to work performed over navigable waters or at the ship’s side.
3. Whether the “point of rest” doctrine can limit LHWCA coverage for workers performing steps in the integrated loading/unloading process.

## Decision

- The Supreme Court affirmed the Fifth Circuit.
- Ford and Bryant were engaged in “maritime employment” because they performed intermediate steps in moving cargo between ship and land transportation.
- The Court treated “maritime employment” as an occupational concept separate from situs and rejected coverage limits based on the “point of rest” doctrine.

## Legal Principles

- After the 1972 amendments, LHWCA coverage requires both: (1) a covered situs under § 3(a) and (2) covered status under § 2(3), and the two requirements have distinct meanings.
- “Maritime employment” in § 2(3) is defined by the nature of the worker’s activities, not by whether the work occurs over water.
- The word “including” in § 2(3) identifies examples within a broader class; longshoremen and persons in longshoring operations are illustrative, not an exclusive list.
- Workers who perform intermediate steps in the movement of cargo between ship and land transportation fall within “maritime employment” when their tasks are part of the integrated loading/unloading process.
- The “point of rest” theory improperly fragments cargo handling and is inconsistent with Congress’s goal of preventing workers from moving in and out of federal coverage based on minor shifts in where cargo momentarily rests.

## Conclusion

The Court held that land-based port workers who perform intermediate cargo-transfer tasks integral to moving goods between vessels and land transportation satisfy the LHWCA’s “maritime employment” status requirement when injured on a covered situs, and it rejected the “point of rest” limitation on coverage.


P.C. Pfeiffer Co. v. Ford, 444 U.S. 69 (1979)