Metropolitan Stevedore Company v. Rambo (1994)
- Docket
- 94-820
- Decided
- 1994-01-01
Summary
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? Conclusion: Yes. In an 8-1 opinion delivered by Justice Anthony M. Kennedy, the Court held that a disability award may be modified under the LHWCA where there is a change in the employee's wage-earning capacity, even without any change in the employee's physical condition. The Court reasoned that, because an interpretation of the term "change in conditions" to include not only changes in physical condition but also changes in other conditions relevant to the initial entitlement to benefits, such as a change in wage-earning capacity is consistent with the purpose of the LHWCA. Justice John Paul Stevens dissented, arguing that the term refers to the physical condition of the person receiving compensation and should not be departed from absent any indication from Congress.