Lykes Bros. S. S. Co. v. Sheppeard
C. B. Stansfield, a longshoreman, sustained a left shoulder injury in 1938 while working for Lykes Bros. Steamship Company, leading to an initial workers' compensation award in 1939 for 15% permanent partial disability. The Deputy Commissioner later modified this award in February 1941, granting additional compensation, citing a "mistake in a determination of fact" after discovering that Stansfield's dislocated clavicle caused pressure on his trachea, a condition not initially known. Lykes Bros. Steamship Company sought judicial review to enjoin the enforcement of this modified award. Judge Kennerly of the District Court found that Stansfield had withheld information regarding his breathing issues from the Deputy Commissioner during the initial proceedings. Consequently, the court ruled that an employee cannot lawfully obtain a modification under Section 922 by withholding material facts, thus granting Lykes Bros. Steamship Company its decree enjoining the enforcement of the February 1, 1941, award.