## Facts

- Christopher S. Sidwell worked for Express Container Services, Inc. (ECS) as a container mechanic repairing cargo containers and chassis used in maritime shipping.
- ECS previously operated near a marine terminal in Portsmouth, Virginia, but relocated in 1985 to a facility about eight-tenths of a mile from the terminal after terminal expansion.
- The relocated facility was surrounded by inland businesses and residential areas and did not border navigable waters.
- On June 11, 1990, Sidwell was injured while repairing a shipping container at the relocated facility.
- ECS paid temporary total disability benefits and medical expenses under Virginia workers’ compensation for a limited period.
- Sidwell sought additional benefits under the Longshore and Harbor Workers’ Compensation Act (LHWCA), 33 U.S.C. § 901 et seq.

## Issues

1. Whether the site of injury satisfied the LHWCA’s situs requirement under 33 U.S.C. § 903(a), specifically whether the facility was an “other adjoining area” to navigable waters.
2. Whether an inland container-repair facility that is functionally related to maritime commerce but not physically contiguous with navigable waters can qualify as a covered LHWCA situs.

## Decision

- The court affirmed the denial of LHWCA benefits.
- The court held the injury site was not a covered situs because it did not “adjoin” navigable waters.
- Because situs was not met, the court treated the coverage dispute as resolved without reaching other potential coverage questions.

## Legal Principles

- LHWCA coverage requires satisfaction of both: (1) status (maritime employment) and (2) situs (a covered location under § 903(a)).
- “Adjoining” in § 903(a) is a geographic term: a covered “adjoining area” must be contiguous with or touch navigable waters.
- Functional connection to maritime activity cannot substitute for the statute’s geographic situs requirement.
- Tests that extend “adjoining area” coverage based primarily on functional relationship, without physical contiguity to water, impermissibly expand § 903(a) beyond its text.

## Conclusion

The Fourth Circuit construed “adjoining area” under the LHWCA as requiring physical contiguity with navigable waters and held that a container-repair facility located roughly 0.8 miles inland from a marine terminal did not satisfy the situs requirement, barring federal longshore benefits.


Sidwell v. Express Container Servs., Inc., 71 F.3d 1134 (4th Cir. 1995)