The US Supreme Court [official website] ruled unanimously [opinion, PDF] Wednesday in Pacific Operators Offshore LLP v. Valladolid [SCOTUSblog backgrounder] that the Outer Continental Shelf Lands Act (OCSLA) [43 USC §§ 1331-1356 text] extends coverage to an employee who can establish a substantial nexus between his injury and his employer's extractive operations on the outer continental shelf (OCS). The OCSLA governs those who work on oil drilling platforms and other fixed structures beyond state maritime boundaries, and workers are eligible for compensation for "any injury occurring as the result of operations conducted on the [OCS]." Juan Valladolid worked for Pacific Operations Offshore, stationed primarily on an offshore drilling platform, but was killed on the grounds of Pacific Operations' onshore oil processing facility when he was crushed by a forklift. The US Court of Appeals for the Ninth Circuit ruled [opinion, PDF] in favor of Valladolid's estate. In an opinion by Justice Clarence Thomas, the court affirmed:
Although the Ninth Circuit’s test may not be the easiest to administer, it best reflects the text of §1333(b), which establishes neither a situs-of-injury nor a "but for" test. We are confident that ALJs and courts will be able to determine whether an injured employee has established a significant causal link between the injury he suffered and his employer's on-OCS extractive operations. Although we expect that employees injured while performing tasks on the OCS will regularly satisfy the test, whether an employee injured while performing an off-OCS task qualifieslike Valladolid, who died while tasked with onshore scrap metal consolidationis a question that will depend on the individual circumstances of each case.Justice Scalia authored a concurrence, which was joined by Justice Samuel Alito.
Wednesday's ruling settles a split among the circuit courts. The court heard arguments [JURIST report] in the case in October. Pacific Operators Offshore argued that the OCSLA has no remedy for an injury that occurred on dry land, but rather Valladolid should have sought relief through state workers compensation law. The federal government argued that the OCSLA covers injuries or death on dry land explicitly, but not under the "nexus" reasoning the Ninth Circuit utilized. Valladolid's attorney argued that, pursuant to similar treatment in the Jones Act [text], his client's estate should be compensated for his death that occurred on land.