Roberts v. Sea-Land Services, Inc.

Under the Longshore and Harbor Workers' Compensation Act, an injured employee's compensation benefits are determined by the date of injury and not the date an award is issued.

After his employer discontinued voluntary workers compensation payments in 2005 for an injury he received in 2002, Petitioner filed a claim with the Department of Labor's Office of Workers' Compensation Programs and an ALJ awarded the 2002 statutory maximum under the Longshore and Harbor Workers’ Compensation Act (LHWCA).

Petitioner filed a motion for reconsideration with the ALJ arguing that the "newly awarded compensation" should be based on the date of the ALJ’s order and not the date of the injury. The ALJ denied the motion for reconsideration and the Department of Labor Benefits Review Board and the Court of Appeals for the Ninth Circuit affirmed.

The Supreme Court affirmed due to the potential negative repercussions of basing the compensation amount on the order date, such as: making it more difficult for an employer to calculate benefit costs; granting disparate awards to similarly situated employees; rewarding employees who initiate unnecessary administrative proceedings in order to secure higher rates; and because it would frustrate the LHWCA's purpose in compensating employees for the wages the employee was receiving at the time of injury. The Court held that “an employee is ‘newly awarded compensation’ when he first becomes disabled and thereby becomes statutorily entitled to benefits, no matter whether, or when, a compensation order issues on his behalf.”