Workers’ Compensation · Primary-source case analysis

Nacirema: A Fixed Pier Was Land Under the Pre-1972 Longshore Act

By Aneeta Mishra and Timothy Chan

Published August 16, 2026

Nacirema Operating Co. v. Johnson reviewed one death and two injuries suffered on fixed piers while longshore workers connected cargo from railroad cars to ships’ cranes under the Act’s pre-1972 water-based coverage language.

The accidents occurred on shore-connected piers

The workers were handling cargo between railcars and ships, but each accident occurred on a pier permanently affixed to land. The question was whether that location counted as injury upon navigable waters under the 1927 Act.

A fixed pier was treated as an extension of land

The Court applied the settled admiralty understanding that a pier attached to shore was land for locality purposes. The federal compensation statute therefore did not reach these pier injuries under its original situs language.

Expanded admiralty tort jurisdiction did not expand compensation coverage

The Admiralty Extension Act could bring some ship-caused land injuries within maritime tort jurisdiction, but it did not rewrite the Longshore Act’s separate compensation boundary.

The 1972 amendments changed the governing map

Congress later extended Longshore coverage to specified adjoining areas and added an occupational-status requirement. Nacirema explains the former shoreline gap; modern claims require the amended statute, later Supreme Court decisions, and current circuit law.

Key takeaways

• Fix the exact injury location and whether the structure is permanently attached to land.
• Apply both modern situs and maritime-status requirements rather than the pre-1972 rule alone.
• Analyze state compensation coverage and federal Longshore coverage separately.
• Preserve facility maps, cargo movement evidence, and the worker’s regular duties.