Pacific Operators Offshore v. Valladolid (2011)
- Docket
- 10-507
- Decided
- 2011-01-01
Summary
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? Conclusion: No. In a 9-0 decision, Justice Clarence Thomas wrote the majority opinion affirming the lower court and remanding for further proceedings. The Supreme Court held that the "substantial nexus" test best represents the text of the OCSLA. The Court noted that persons injured on the Outer Continental Shelf would almost always satisfy this test. The outcome for persons injured in other locals, like Mr. Valladolid, would depend on the individual circumstances of the case. On remand the Valladolid's must show a significant causal link between Mr. Valladolid's death and Pacific's Outer Continental Shelf activities. Justice Antonin Scalia wrote a special concurrence, stating that "substantial nexus" is just legalese with no established meaning. He felt this test would be impossible to apply. He would apply a proximate cause test, which has been defined by tort law. Justice Samuel Alito joined in the concurrence.