A-Z International Great American Insurance Company v. Michael James Phillips

A-Z International and its insurer, Great American Insurance Company, (collectively “A-Z”) appeal from the decision of the district court dismissing A-Z’s action with prejudice. A-Z filed a complaint in the district court, seeking, inter alia, enforcement of an administrative law judge’s (“ALJ”) order certifying facts and recommending sanctions, pursuant to § 927(b) of the Longshore and Harbor Workers’ Compensation Act (“LHWCA”), 33 U.S.C. § 927 (b) (2003), for Michael James Phillips’s conduct before the ALJ.

We must decide whether § 927(b) authorizes a district court to sanction a claimant for contempt for filing a false claim for benefits under the LHWCA. We affirm the dismissal of this action because we conclude that a district court lacks subject-matter jurisdiction to sanction a party for contempt under such circumstances.

I

In September 1998, Phillips filed a claim for benefits against his employer, A-Z, alleging injury on an offshore oil rig, the Hermosa, and seeking benefits under the LHWCA, 33 U.S.C. §§ 901-950 , as extended by the Outer Continental Shelf Lands Act (“OCSLA”), 43 U.S.C. §§ 1331-1356 (2000). On March 26, 1993, the ALJ denied Phillips’s claim. The…