Workers’ Compensation · Primary-source case analysis

Calbeck: The Longshore Act Reached Injuries on Navigable Waters Even Where State Compensation Might Apply

By Aneeta Mishra and Timothy Chan

Published August 20, 2026

Calbeck v. Travelers Insurance Co. consolidated claims involving ship-construction workers injured or killed while working aboard vessels afloat on navigable waters.

Congress sought dependable federal coverage on navigable waters

The Court rejected a construction that would make federal protection turn on uncertain, case-by-case constitutional boundaries of state power.

Possible state coverage did not defeat the federal claim

The statutory phrase concerning compensation that could not validly be provided by state law was read in light of Congress’s purpose to prevent remedial gaps.

The injury location and employment still mattered

The claims involved maritime work aboard vessels on navigable waters, not every land-based injury connected in some way to shipping.

The 1972 amendments changed the framework

Modern Longshore cases apply separate situs and occupational-status requirements and may allow concurrent state remedies under later decisions. Calbeck supplies historical foundation, not a substitute for the current statute.

Key takeaways

• Identify the exact injury location and the worker’s regular duties.
• Analyze current Longshore situs and status separately.
• Check whether a state compensation remedy may run concurrently.
• Preserve notice and limitations rights in every potentially applicable system.