In the case of Metropolitan Stevedore Company v. John Rambo et al., 1996, the U.S Supreme Court was tasked with determining whether an administrative law judge (ALJ) could reconsider a disability benefits award under the Longshore and Harbor Workers' Compensation Act without first finding a "mistake in a determination of fact". The court ruled that an ALJ has this authority. The case involved John Rambo, who had been awarded permanent total disability benefits after being injured while working for Metropolitan Stevedore Company. Later on, he found lighter work which paid more than his previous job at Metropolitan. As such, Metropolitan sought to have his benefit payments reduced or terminated arguing that Rambo's improved earning capacity constituted a change in conditions warranting modification of his award under Section 22 of the act. The Supreme Court agreed with this argument stating that changes in economic circumstances can be considered as changed conditions allowing for modification even if there is no factual mistake made during initial determinations.

In the dissenting opinion for Metropolitan Stevedore Company v. John Rambo et al., Justice Ginsburg disagreed with the majority's interpretation of "newly awarded compensation" under Section 8(f) of the Longshore and Harbor Workers' Compensation Act (LHWCA). She argued that this phrase should be interpreted to mean when an employer is first held liable for a worker's disability, not when an administrative law judge issues a formal compensation order. This interpretation would better align with Congress’s intent in enacting LHWCA - to encourage employers to hire disabled workers by limiting their liability for any subsequent work-related injuries those employees might suffer. The majority’s decision, she contended, could discourage employers from voluntarily paying benefits because they might fear losing potential relief under Section 8(f). Furthermore, it may delay payments to injured workers as employers wait for formal orders before starting payments. Thus, Ginsburg believed that her interpretation was more consistent with both statutory language and policy objectives.