Director, Office of Workers’ Compensation Programs, Department of Labor v. Newport News Shipbuilding and Dry Dock Co.

The Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA) created a system for compensating workers killed or injured on the navigable waters of the United States. The United States Department of Labor was tasked with enforcing the LHWCA and delegated most of that power to the director of the Office of Workers’ Compensation Programs (the director) (plaintiff). Injured workers submitted claims to a local office. Administrative-law judges made the initial decisions, the Benefits Review Board (the board) reviewed the decisions of the administrative-law judges, and the appropriate United States court of appeals reviewed the decisions of the board. The director was not involved in any of the adjudication, and the LHWCA did not provide that the director had standing to appeal adjudicatory decisions. Rather, the LHWCA provided that only those parties adversely affected or aggrieved by an agency decision had standing to challenge those decisions with the agency or the courts. Jackie Harcum, an employee of Newport News Shipbuilding and Dry Dock Co. (Newport Shipbuilding) (defendant), was injured while working. Harcum applied for benefits under the LHWCA. An administrative-law judge held that Harcum was partially disabled and entitled to partial-disability benefits. The board affirmed the administrative-law judge and further held that Newport Shipbuilding could stop paying Harcum benefits after 104 weeks. The director petitioned the United States Court of Appeals for the Fourth Circuit for review of the board’s decision. Harcum was not involved in the appeal. The court of appeals determined that the director did not have standing to appeal the board’s order, because the director was not adversely affected or aggrieved by the board’s decision. The director appealed. The United States Supreme Court granted certiorari.