Washington v. W. C. Dawson & Co.
1924 U.S. LEXIS 2498, 44 S. Ct. 302, 264 U.S. 219 (1924)
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Rule of Law:
Congress cannot constitutionally delegate its exclusive power to legislate on maritime matters to the states. An act of Congress permitting states to apply their individual workmen's compensation laws to maritime injuries is unconstitutional as it violates the constitutional principle of uniformity in general maritime law.
Facts:
- W. C. Dawson & Co. was engaged in the business of stevedoring in Washington state.
- Its employees worked exclusively aboard ships in the navigable waters of Puget Sound.
- The State of Washington sought to compel the company to contribute to the state's mandatory workmen's compensation accident fund for these employees.
- In a separate but related case, a workman was killed in California while discharging cargo from a vessel moored in San Francisco Bay.
- The workman was performing maritime work under a maritime contract at the time of his death.
- A claim for death benefits was filed under California's state workmen's compensation law.
Procedural Posture:
- In one case, the State of Washington sought to compel W. C. Dawson & Co. to contribute to the state workmen's compensation fund.
- The Supreme Court of Washington held that the state could not apply its law because the authorizing Act of Congress was unconstitutional.
- In a second case, the Industrial Accident Commission of California attempted to award benefits for the death of a maritime worker.
- The Supreme Court of California also declared the federal act unconstitutional and held that the state commission lacked jurisdiction.
- The State of Washington and the Industrial Accident Commission of California, the losing parties in their respective state supreme courts, appealed to the U.S. Supreme Court, which consolidated the cases.
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Issue:
Does the Act of Congress of June 10, 1922, which authorizes the application of state workmen's compensation laws to injuries within federal admiralty and maritime jurisdiction, unconstitutionally delegate Congress's legislative power and destroy the uniformity of maritime law?
Opinions:
Majority - Mr. Justice McReynolds
Yes, the Act unconstitutionally delegates power. The Act of Congress of June 10, 1922, is an unconstitutional delegation of legislative power because it destroys the uniformity of maritime law. The Court's prior holdings in Southern Pacific Co. v. Jensen and Knickerbocker Ice Co. v. Stewart are controlling. The Constitution's grant of admiralty and maritime jurisdiction to the federal government was intended to establish harmonious and uniform rules for maritime commerce, freeing it from the burdens of 'discordant legislation' by the various states. While Congress has the power to alter maritime law, it must do so through general statutes that apply uniformly across the nation. The power to legislate on this national subject cannot be delegated to the states, as such delegation would 'inevitably destroy the harmony and uniformity which the Constitution not only contemplated but actually established.' The 1922 Act, like the 1917 Act struck down in Knickerbocker, attempts such an unconstitutional delegation, and the minor exception for a vessel's master and crew is insufficient to cure this fundamental defect.
Dissenting - Mr. Justice Holmes
No, the Act does not unconstitutionally delegate power. Justice Holmes stated that the reasoning of Southern Pacific Co. v. Jensen and its subsequent cases never satisfied him. While he would have welcomed a limit being set to the principle of federal uniformity in this context, he felt he must leave it to the majority, who believe the principle is correct, to determine how far it extends.
Dissenting - Mr. Justice Brandeis
No, the Act does not unconstitutionally delegate power. The Act is a constitutional exercise of Congress's power to regulate maritime law and determine where uniformity is not required. The majority's conclusion rests on a flawed chain of reasoning. Applying a state's workmen's compensation law to a local employment relationship, even when the injury occurs on a vessel, is an exercise of the state's police power that does not materially prejudice the characteristic features of maritime law or interfere with its uniformity in interstate and international relations. Congress, which holds the power over maritime law, is best positioned to decide which areas require absolute uniformity and which can accommodate local regulation. The Court should frankly overrule Jensen and Knickerbocker because the rule they established is legally unsound, creates unfortunate social and economic consequences for injured workers, and frustrates a needed legislative remedy. Stare decisis should not prevent the Court from correcting a recent and erroneous line of decisions.
Analysis:
This case represents the high-water mark of the 'Jensen doctrine,' which required strict national uniformity in maritime law. By striking down Congress's second attempt to allow state workmen's compensation laws to apply to maritime workers, the Court solidified the principle that Congress's power in this area is non-delegable. This decision effectively closed the door on state-based solutions and compelled Congress to create a uniform federal remedy. This led directly to the passage of the federal Longshoremen's and Harbor Workers' Compensation Act (LHWCA) in 1927, which remains the primary compensation scheme for injured maritime workers today.
