Metropolitan Stevedore Company v. Rambo

PETITIONER: Metropolitan Stevedore Company
RESPONDENT: Rambo
LOCATION: Spendthrift Farm

DOCKET NO.: 94-820
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 515 US 291 (1995)
ARGUED: Apr 25, 1995
DECIDED: Jun 12, 1995

ADVOCATES:
Jeffrey P. Minear - Argued the cause for the Federal respondent supporting the petitioner
Robert E. Babcock - Argued the cause for the petitioner
Thomas J. Pierry, III - Argued the cause for the respondents

Facts of the case

John Rambo received a disability award under the Longshore and Harbor Workers' Compensation Act (LHWCA) for an injury he sustained while working for the Metropolitan Stevedore Company as a longshore frontman. Afterwards, Rambo acquired new skills and obtained longshore work as a crane operator, earning more than three times his preinjury earnings, though his disabled physical condition remained unchanged. Metropolitan filed to modify Rambo's disability award under the LHWCA on the ground that there had been a change in conditions such that Rambo was no longer disabled. An Administrative Law judge terminated Rambo's benefits. The Benefits Review Board affirmed. In reversing, the Court of Appeals held that the LHWCA authorizes modification only where there has been a change in an employee's physical condition.

Question

Does the Longshore and Harbor Workers' Compensation Act allow a party to seek modification of a disability award on the ground of change in conditions, when there has been no change in the employee's physical condition but rather an increase in the employee's wage-earning capacity due to the acquisition of new skills?

Media for Metropolitan Stevedore Company v. Rambo

Audio Transcription for Oral Argument - April 25, 1995 in Metropolitan Stevedore Company v. Rambo

Audio Transcription for Opinion Announcement - June 12, 1995 in Metropolitan Stevedore Company v. Rambo

William H. Rehnquist:

The opinion of the Court number 94-820 Metropolitan Stevedore Co. versus Rambo will be announced by Justice Kennedy.

Anthony M. Kennedy:

This is a case that arrives under the Longshore and Harbor Workers' Compensation Act.

When a worker is covered by the Act sustains an injury, the Act has a comprehensive scheme to compensating for loss in wage-earning capacity.

There are two kinds of injuries, one is an injury which is on a schedule usually for the loss of a limb and the other is so-called non-scheduled injuries, which is what's involved here, the employee injured is back.

He received an award because of the injury he’d lost wage-earning capacity.

He then attended a school for training as acrane operator and for operating heavy equipment, and he became a crane operator and his earnings capacity is a result increased, he increased quite substantially.

The employer sought a modification of the award and cited the statute but says an award can be modified if there is achange in conditions.

The employee, the worker said changing conditions means only physical condition and my back is still injured.

The employer said, no, it means also a change in your wage-earning capacity.

We took the case up because the circuits are in disagreement on this point.

We agree with the employer that a change inconditions under the statute, he includes a change in wage-earning capacity.

Disability is an economic concept not a medical concept.

Accordingly, we reverse the judgment of the Ninth Circuit where this case rose and remanded the case for further proceedings.

Justice Stevens has filed a dissent.