San Diego Law Review

Library of Congress Authority File


Document Type



This Comment examines the recent Congressional decision that individuals employed exclusively to perform security work are no longer covered under the Longshore and Harbor Workers' Compensation Act (LHWCA). The author argues that watchmen had been traditionally covered both before and after Congress added a "status" test for coverage in 1972. Examining the pre and post-1972 decisional history, the author argues that because Congress eliminated the jurisdictional dilemma which formerly served as the main justification for extending LHWCA coverage, the 1984 LHWCA amendments excluding coverage are consistent with those previous judicial decisions extending coverage to watchmen.