Pacific Operators Offshore v. Valladolid

PETITIONER: Pacific Operators of Offshore, LLP, et al.
RESPONDENT: Luisa L. Valladolid
LOCATION: U.S. Congress

DOCKET NO.: 10-507
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 565 US (2012)
GRANTED: Feb 22, 2011
ARGUED: Oct 11, 2011
DECIDED: Jan 11, 2012

ADVOCATES:
David C. Frederick - for the private respondent
Joseph R. Palmore - Assistant to the Solicitor General, Department of Justice, for the federal respondent
Paul D. Clement - for the petitioners

Facts of the case

Pacific Operations Offshore runs two offshore oil drilling platforms, the Hogan and the Houchin, both located more than three miles off the coast of California. Juan Valladolid worked for Pacific Operations as a roustabout, stationed primarily on the Hogan. He was killed, however, on the grounds of Pacific Operations's onshore oil-processing facility when he was crushed by a forklift. Following his death, his widow, Luisa, sought workers' compensation benefits under the Outer Continental Shelf Lands Act ("OCSLA") and the Longshore and Harbor Workers' Compensation Act ("LHWCA"). An administrative law judge denied Mrs. Valladolid's OCSLA claim on the grounds that her husband's injury had occurred outside the geographic site of the outer continental shelf. The judge denied the LHWCA claim on two grounds: (1) Valladolid was not engaged in maritime employment, and (2) he was not injured on a maritime situs. The Benefits Review Board upheld the judge's denial of the OCSLA benefits under the "situs-of-injury" test, and affirmed the denial of LHWCA benefits on the maritime situs ground.

The United States Court of Appeals for the Ninth Circuit reversed in part, ruling that the OCSLA does not have a situs-of-injury requirement. The court of appeals held that Section 1333(b) extends Longshore Act coverage to workers injured on land where there is "a substantial nexus between the injury and extractive operations on the shelf." Two other circuits that have addressed the question have reached conflicting results.

Question

The Outer Continental Shelf Lands Act extends workers' compensation coverage under the Longshore and Harbor Workers' Compensation Act "with respect to disability or death of an employee resulting from any injury occurring as the result of operations conducted on the outer Continental Shelf for the purpose of exploring for, developing, removing, or transporting by pipeline the natural resources of the outer Continental Shelf." Does the OCSLA extend Longshore Act coverage only to workers injured on the outer Continental Shelf itself?

Media for Pacific Operators Offshore v. Valladolid

Audio Transcription for Oral Argument - October 11, 2011 in Pacific Operators Offshore v. Valladolid

Audio Transcription for Opinion Announcement - January 11, 2012 in Pacific Operators Offshore v. Valladolid

John G. Roberts, Jr.:

Justice Thomas has our opinion in case 10-507, Pacific Operators Offshore versus Valladolid.

Clarence Thomas:

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit.

Petitioner operates two oil platforms on the Outer Continental Shelf off the coast of California, one by Valladolid, one of petitioner's employees spent most of his time working on one of these offshore platforms, but he was killed in an accident while working at petitioner's onshore facility.

Valladolid's widow, the respondent here, sought workers' compensation benefits pursuant to the Outer Continental Shelf Lands Act.

The Lands Act extends the workers' compensation coverage provided by another statute, the Longshore and Harbor Workers' Compensation Act to injuries occurring as a result of operations conducted on the Shelf for the purpose of extracting natural resources.

An administrative law judge dismissed the respondent's claim reasoning that the Lands Act did not cover Valladolid's fatal injury because his accident occurred on land rather than on the Shelf.

The Labor Department's Benefit Review Board affirmed.

The Ninth Circuit reversed, concluding that the Lands Act did not incorporate a strict geographic restriction, but rather required a substantial nexus between a worker's injury and his employer's extractive operations on the Shelf.

In an opinion filed with the clerk today, we affirm.

We reject the petitioner's argument that the Lands Act extends Longshore Act coverage only to employees whose injuries occur on the Shelf.

Nothing in the text of the Lands Act supports such a restriction.

The statute has only two requirements, the employer's extractive operations must be conducted on the Shelf and the employee's injury must occur as a result of those operations.

Had Congress intended to limit the scope of Lands Act coverage solely to injuries that occur on the Shelf then Congress could have easily done so as demonstrated by the explicit geographic restrictions that appear in other subsections of the Act.

We are also unpersuaded by petitioner's alternative argument which requires a nonintuitive reading of the Lands Act in light of other unrelated provisions in the Longshore Act.

We find it unlikely that Congress intended to restrict the scope of -- of the Lands Act Workers' Compensation scheme through the convoluted combination of two separate legislative Acts.

Instead, we conclude that the substantial nexus test faithfully interprets the text of the Lands Act.

We understand that test to require an injured employee to establish a significant causal link between his injury and his employer's extractive operations on the Shelf in order to be eligible for workers' compensation benefits under the Lands Act.

Whether an injured employee qualifies for Lands Act coverage will depend on the specific circumstances of his case.

It was thus proper for the Ninth Circuit to remand this case for the Benefits Review Board to apply the substantial nexus test to the circumstances presented in this case.

Justice Scalia has filed an opinion concurring in part and concurring in the judgment in which Justice Alito joins.

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