In the case of Sharon B. Pollard v. E.I du Pont de Nemours & Company, 2000, the Supreme Court ruled in favor of DuPont on a workers' compensation claim filed by Pollard. The court held that an employer's liability under the Longshore and Harbor Workers' Compensation Act (LHWCA) is limited to disability benefits and medical expenses related to work-related injuries or illnesses; it does not extend to additional damages for pain and suffering or loss of consortium due to negligence causing such injury or illness. This decision was based on Section 5(b) of LHWCA which provides employers immunity from further claims if they secure payment of compensation for their employees as required by law.

In the dissenting opinion for Sharon B. Pollard v. E.I du Pont de Nemours & Company, Justice Stevens argued that the majority's decision to bar claims under Title VII of the Civil Rights Act of 1964 was incorrect and inconsistent with Congress' intent when it enacted this law. He contended that a claimant should not be barred from seeking relief just because they had previously filed an unsuccessful disability discrimination claim under a different statute (the Americans with Disabilities Act). The justice believed that each act provides distinct rights and remedies, so filing one type of claim should not preclude another. Furthermore, he disagreed with the majority's interpretation of 'election-of-remedies' doctrine as he felt it contradicted legislative history and precedent which supported allowing multiple avenues for redress in cases like these.