Workers’ Compensation · Primary-source case analysis

Pfeiffer: Landside Cargo Work Was Maritime Employment Under the Longshore Act

By Aneeta Mishra and Timothy Chan

Published September 8, 2026

P. C. Pfeiffer Co. v. Ford considered Longshore Act coverage for two landside workers who handled military vehicles and cotton while cargo moved between ships, warehouses, and inland transportation.

Two workers handled cargo between sea and land transportation

Ford was injured on a public dock while fastening military vehicles onto railroad flatcars after the vehicles arrived by ship. Bryant was injured moving cotton from a dray wagon into a pier warehouse before later ship loading.

The lower tribunals rejected a point-of-rest cutoff

Administrative law judges denied coverage under a theory limiting maritime employment to cargo work on the ship side of its last resting point. The Benefits Review Board and Fifth Circuit rejected that narrow boundary.

Status and situs were distinct statutory requirements

The Court explained that the amended Act separately asks where the injury occurred and whether the worker performed maritime employment. Congress anticipated that some employees working only on land would satisfy the occupational status test.

Intermediate cargo steps were maritime employment

Both workers performed tasks traditionally done by longshore workers and were integral to moving goods between ship and land transportation. The unanimous Court affirmed coverage.

Key takeaways

• Identify the precise cargo movement underway when the injury occurred.
• Analyze statutory situs and occupational status separately.
• Avoid treating a temporary cargo resting point as an automatic coverage cutoff.
• Document the worker’s regular and assignable duties across the loading or unloading process.