Roberts v. Sea-Land Services, Inc.
132 S. Ct. 1350
| SCOTUS | 2012Background
- LHWCA caps disability benefits at 200% of the national average weekly wage for the year an employee is first newly awarded compensation.
- Most benefits are paid voluntarily by employers; formal compensation orders arise only if liability is controverted or disputed.
- Roberts was injured in 2002; employer voluntarily paid benefits for a period, then ceased; later an ALJ awarded benefits at the statutory max for 2002.
- Roberts argued the cap should be based on the fiscal year in which the compensation order was issued (the order year).
- The Ninth Circuit affirmed Roberts; the Supreme Court granted certiorari to resolve the circuit split.
- The Court holds that “newly awarded compensation” means first becoming statutorily entitled to benefits, regardless of order timing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Definition of 'newly awarded compensation' §906(c) | Roberts: ‘awarded’ means formal order issued. | Sea-Land: ‘awarded’ means statutorily entitled due to disability. | Employee is newly awarded when first statutorily entitled, regardless of order. |
| Does reading 'awarded' as entitlement render §906(c) superfluous? | If order timing governs, late orders would be unnecessary. | A formal order is not always present; need universal cap rule. | No; the entitlement reading preserves the statute’s coherent caps for all cases. |
| Administrative feasibility and interpretation | Order-based approach aligns with formal adjudication. | Entitlement approach reduces gaming and aligns with administrative structure. | Entitlement-based interpretation coheres with administrative processes and prevents manipulation. |
Key Cases Cited
- Metropolitan Stevedore Co. v. Rambo, 515 U.S. 291 (1995) (disability definitions under LHWCA for compensation)
- Rasmussen, 440 U.S. 29 (1979) (survivor benefits and awards terminology)
- Astrue v. Ratliff, 560 U.S. 586 (2010) (statutes that award attorney’s fees to a prevailing party)
- Barber v. Thomas, 560 U.S. 474 (2010) (statutory interpretation of entitlements and awards)
- New Energy Co. of Ind. v. Limbach, 486 U.S. 269 (1988) (statutory meaning of tax credits and awards)
- Pacific Employers Ins. Co. v. Industrial Accident Comm’n, 306 U.S. 493 (1939) (workers’ compensation award language and awards)
- Estate of Cowart v. Nicklos Drilling Co., 505 U.S. 469 (1992) (entitlements vs. award terminology in LHWCA context)
- TRW Inc. v. Andrews, 534 U.S. 19 (2001) (statutory interpretation and coherent regulatory schemes)
- Wilkerson v. Ingalls Shipbuilding, 125 F.3d 904 (5th Cir. 1997) (time of entitlement vs. order timing under LHWCA)
- Pallas Shipping Agency, Ltd. v. Duris, 461 U.S. 529 (1983) (informal payment vs. formal award under LHWCA)