Healy Tibbitts subcontracted with John Mannering to build the main duct bank. The District Director of the Department of Labor's Office of Workers' Compensation Programs ("OWCP") referred this case to an Administrative Law Judge, who conducted an evidentiary hearing on May 23, 2002. Healy Tibbitts and Mannering petitioned for review. ANALYSIS To qualify for benefits, an individual must be an "employee" as that term is defined in the Act. Instead, the controversy in this case centers on the terms "maritime employment" and "harbor worker," both of which the Act leaves undefined.

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