In the 1939 case South Chicago Coal & Dock Co. et al. v. Bassett, Deputy Commissioner, the U.S Supreme Court ruled in favor of Bassett, upholding a decision by the deputy commissioner under the Longshoremen's and Harbor Workers' Compensation Act to award compensation for permanent total disability to an employee who had lost his leg due to injury at work. The court held that it was not necessary for there to be a complete physical or mental incapacity before such benefits could be awarded; rather, if an employee is unable to secure any type of regular employment because of their injuries then they are considered totally disabled within the meaning of this act. The employers argued that since he could still perform some tasks like being a watchman or elevator operator he wasn't completely incapacitated but this argument was rejected by Justice Black stating "total disability" does not mean absolute helplessness.

In the dissenting opinion for South Chicago Coal & Dock Co. et al. v. Bassett, Deputy Commissioner, Justice McReynolds disagreed with the majority's decision that a federal deputy commissioner had jurisdiction to award compensation under the Longshoremen's and Harbor Workers' Compensation Act for an injury sustained on navigable waters within Illinois state boundaries. He argued that Congress did not have authority over such matters because they fell under state jurisdiction according to Article III of the Constitution which limits federal judicial power to cases involving maritime law or those between states or citizens of different states. Therefore, he believed it was unconstitutional for a federal officer to adjudicate in this case as it involved neither interstate dispute nor maritime law but rather concerned local matters pertaining solely to Illinois.