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Foster v. Dravo Corp.

• 1974 • 420 U.S. 92 • Burger Court
In the case of Foster v. Dravo Corp., 1974, the United States Supreme Court dealt with a dispute over workers' compensation for an employee who was injured while working on a barge in navigable waters. The plaintiff, Foster, argued that he should be able to sue his employer under general maritime law because his injury occurred on navigable waters and thus fell within federal jurisdiction. However, the defendant company countered that since they were not engaged in traditional maritime activity...Open Case
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Chief Burger Court
Term: 1974
Docket: 73-1773
420 U.S. 92
95 S. Ct. 879
43 L. Ed. 2d 44
1975 U.S. LEXIS 149
Argued: Jan 20, 1975

Foster v. Dravo Corp.

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Opinion Summary
AI Abstract

In the case of Foster v. Dravo Corp., 1974, the United States Supreme Court dealt with a dispute over workers' compensation for an employee who was injured while working on a barge in navigable waters. The plaintiff, Foster, argued that he should be able to sue his employer under general maritime law because his injury occurred on navigable waters and thus fell within federal jurisdiction. However, the defendant company countered that since they were not engaged in traditional maritime activity at the time of the accident but rather construction work related to river transportation infrastructure (building locks), their activities did not fall under federal admiralty jurisdiction and therefore state workers’ compensation laws applied instead. The Supreme Court ruled in favor of Dravo Corporation stating that although Foster's injury took place on navigable waterways which would typically invoke federal jurisdiction under maritime law; however, it also recognized an exception where if employment is land-based and worker’s injuries sustained during non-maritime work then state workers' compensation laws apply instead. This decision helped clarify when state versus federal regulations apply in cases involving accidents occurring near or on bodies of water.

Dissent Summary
AI Abstract

In the dissenting opinion for Foster v. Dravo Corp., the justice disagreed with the majority's interpretation of maritime law and its application to this case. The justice argued that, under traditional maritime principles, a vessel owner is not liable for injuries sustained by an independent contractor's employee unless it can be proven that they had control over or knowledge of dangerous conditions on their ship. In this case, there was no evidence presented showing that Dravo Corporation knew about or controlled any hazardous circumstances leading to Foster’s injury. Therefore, according to the dissenting view, liability should not have been imposed on them as per general maritime law principles which were overlooked in favor of state laws by the majority decision.

Opinion written by Justice TMarshall
Decided: Feb 18, 1975
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Argued: Oct 05, 2026
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