The decision in Southern Pacific Co. v. Jensen that state law does not apply to injuries occurring on navigable waters, began a series of jurisdictional questions which continue today. This decision initially deprived some 300,000 longshoremen and harbor workers in dangerous occupations of a compensation remedy, but it paved the way for a federal statute providing them with compensation coverage. Longshoremen and harbor workers are today protected under state or federal law, depending on whether their injuries occur on land or "upon navigable waters." They may be eligible for coverage under both federal and state law.
Richard E. Hendricks, Jurisdiction in Longshoremen's Injuries, 16 Clev.-Marshall L. Rev. 124 (1967)