In the 1982 case Director, Office of Workers' Compensation Programs, United States Department of Labor v. Perini North River Associates et al., the Supreme Court ruled on an issue related to workers' compensation for longshoremen and harbor workers. The court held that a worker who is injured while performing duties upon navigable waters in or adjacent to maritime employment is entitled to receive benefits under the Longshoremen's and Harbor Workers' Compensation Act (LHWCA), regardless of whether their injury was caused by traditional maritime activities. This ruling clarified that "maritime employment" as defined by LHWCA includes any employee engaged in work upon navigable waters, not just those involved in loading, unloading, repairing or building a vessel.

In the dissenting opinion for Director, Office of Workers' Compensation Programs, United States Department of Labor v. Perini North River Associates et al., 1982, Justice Powell argued that the majority's interpretation of the Longshoremen's and Harbor Workers' Compensation Act was overly broad. He contended that Congress intended to limit compensation under this act to workers who were injured while performing tasks traditionally done by longshoremen and harbor workers. The majority’s decision would extend coverage to any worker who happened to be over navigable waters at the time of injury regardless if their work is related or not with maritime employment. This expansion could lead employers in industries unrelated to shipping or dock work being held liable for injuries occurring over water even when they have no control over those conditions - a result he believed Congress did not intend.