Fiscal year for worker benefits
Roberts v. Sea-Land Services
In brief
The Supreme Court upheld the Ninth Circuit: the cap uses the fiscal year when a worker first becomes disabled and entitled to benefits, even if a formal award comes later.
- Where it stands
- Decided
Decided 8-1 · March 20, 2012 · Opinion by Justice Sotomayor
- What it’s about
- Dana Roberts and Sea-Land disputed which fiscal year's wages set the Longshore Act's cap on disability benefits: the year Roberts first became entitled to benefits or the year a formal compensation award was issued.
- Who it affects
- For workers covered by the Longshore Act, the cap is based on the fiscal year they first become disabled and entitled to benefits, not the year a compensation order is issued.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the Ninth Circuit (affirmed its ruling), deciding the relevant year is when a worker first becomes disabled and entitled to benefits, regardless of when an order is issued.
The Longshore Act caps an injured worker's disability benefits at twice the national average weekly wage for a specified fiscal year.
Question presented
Under the Longshore Act, is the period when an individual is newly awarded compensation the fiscal year when an injured worker first becomes entitled to compensation or the fiscal year when the injured worker is actually awarded compensation?
What the Court decided
Holding
An employee is “newly awarded compensation” when he first becomes disabled and thereby becomes statutorily entitled to benefits, no matter whether, or when, a compensation order issues on his behalf. Pp. 5 − 18. 625 F. 3d 1204, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court treated a worker's first disability as the event that creates legal entitlement to benefits; a later compensation order does not change the relevant year.
The vote
From the opinions
“Unlike the Court, however, I do not regard as reasonable respondent Sea-Land Services’ view that an employee is “newly awarded compensation” in the year she becomes “statutorily entitled to compensation.””
What's next
The Ninth Circuit's ruling remains in place. For the cap calculation in Roberts's case, the relevant year is when she first became disabled and entitled to benefits, not when the compensation order issued.
Each side's argument
- Dana Roberts
- Roberts argued that the cap should be based on the fiscal year when she received a formal compensation award.
- Sea-Land Services, Inc.
- Sea-Land argued that the cap should be based on the fiscal year when Roberts first became disabled and legally entitled to benefits.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
New analysis added
AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Roberts
Opinion added: Sea-Land
More questions
- What did Justice Ginsburg disagree with?
- She agreed Roberts's formal-award argument failed, but did not consider Sea-Land's entitlement-based view reasonable.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.