Warner v. Travelers Insurance Company
Warner, an employee of Todd Shipyard Corporation, sustained an eye injury while working on the S.S. Greenwich. He filed a claim with the Industrial Accident Board of Texas, which was dismissed for lack of jurisdiction. Warner then sued in the District Court of Galveston County for $2,950 under Texas Workmen’s Compensation Law, but the case was again dismissed for want of jurisdiction. He appealed this dismissal. The central issue is whether his claim falls under Texas Workmen's Compensation Law or the Federal Longshoremen’s and Harbor Workers’ Act, particularly concerning the "twilight zone" doctrine established in Davis v. Department of Labor. The court analyzed several precedents, distinguishing cases where the work was incidental to non-maritime activities. Ultimately, the court determined that Warner's work was purely maritime, not falling within the "twilight zone," and therefore, the Federal Act provided the exclusive remedy, affirming the trial court's dismissal.