Sidwell v. Express Container Services, Inc.
United States Court of Appeals for the Fourth Circuit
71 F.3d 1134, 1996 AMC 995 (1995)
- Written by Carolyn Strutton, JD
Facts
Express Container Services, Inc. (ECS) (defendant) repaired cargo containers both at a port and at a location that was approximately one mile away from the port terminal. Christopher Sidwell (plaintiff) worked for ECS as a container mechanic, primarily at the site away from the port, and was injured while working in that location. ECS voluntarily paid Sidwell temporary total-disability benefits under a state workers’-compensation program, as well as medical benefits. Sidwell filed a claim for additional compensation under the Longshoremen’s and Harbor Workers’ Compensation Act (LHWCA). The administrative-law judge denied Sidwell benefits under the LHWCA, holding that Sidwell was not entitled to coverage because the site where the injury occurred was not a statutorily covered adjoining area under the functional-relationship test set forth in Brady-Hamilton Stevedore Co. v. Herron. The Benefits Review Board affirmed the decision, and Sidwell appealed.
Rule of Law
Issue
Holding and Reasoning (Luttig, J.)
Concurrence (Beaty, J.)
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