The U.S. Supreme Court case Southwest Marine, Inc. v. Byron Gizoni in 1991 revolved around the question of whether an employee covered by the Longshore and Harbor Workers' Compensation Act (LHWCA) could also seek damages under Section 905(b) of the same act for injuries sustained on navigable waters due to negligence from a vessel owner or operator, even if that employer was their own employer at the time of injury. Byron Gizoni, an employee of Southwest Marine Inc., was injured while working aboard one of his employer's vessels and sought compensation under both provisions. The District Court initially dismissed his claim stating that he couldn't sue his employers as they were protected by LHWCA immunity clause. However, upon appeal to Ninth Circuit court it reversed this decision arguing that nothing in Section 905(b) explicitly precluded such claims against vessel-owning employers. When appealed further to Supreme Court it affirmed Ninth Circuit’s ruling stating there is no explicit language within LHWCA barring employees from seeking additional damages through section 905(b). Therefore workers can indeed sue their maritime employers for negligence leading to workplace injuries.

In the dissenting opinion for Southwest Marine, Inc. v. Byron Gizoni, Justice White disagreed with the majority's interpretation of the Longshore and Harbor Workers' Compensation Act (LHWCA). He argued that Congress intended to provide workers with a choice between seeking compensation under LHWCA or suing their employers under general maritime law for negligence. The majority's decision effectively removed this option by ruling that an injured worker covered by LHWCA could not sue his employer directly unless he could prove intentional harm. According to Justice White, this was inconsistent with previous court rulings and congressional intent as it limited workers' rights to seek full damages from negligent employers in court while also receiving statutory benefits under LHWCA.