In the case of Metropolitan Stevedore Company v. John Rambo et al., 1994, the U.S Supreme Court was tasked with determining whether a worker's compensation award could be modified under certain circumstances. The claimant, John Rambo, had initially been awarded benefits after being injured on the job as a longshoreman for Metropolitan Stevedore Company. However, he later found higher-paying work and sought to have his disability rating reduced so that he would not be overcompensated. The company opposed this modification arguing that it should only apply in cases where there has been an actual physical change in condition or mistake in determination of fact at initial hearing. The Supreme Court ruled unanimously (9-0) in favor of Rambo stating that changes in economic conditions can justify modifying an award under Longshore and Harbor Workers' Compensation Act (LHWCA). Justice Clarence Thomas wrote for the court saying "economic reality" ought to inform decisions about workers' compensation awards; thus allowing modifications based on changes like increased earning capacity even without any physical improvement or correction of factual errors made during original proceedings.

In the dissenting opinion for Metropolitan Stevedore Company v. John Rambo, it was argued that the majority's decision to allow a second hearing for an increase in disability benefits under certain conditions contradicts the Longshore and Harbor Workers' Compensation Act (LHWCA). The dissenting justices believed that this act only allows one modification request per claim, not multiple requests as permitted by the majority ruling. They also contended that allowing multiple modifications could lead to endless litigation and uncertainty for both employers and employees. Furthermore, they disagreed with the majority's interpretation of "mistake in a determination of fact" which would trigger another modification proceeding; instead arguing such mistakes should be limited to clerical errors or misinterpretations of medical reports rather than changes in condition over time.